RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
LCP-HOLTRACHEM SUPERFUND ALTERNATIVE SITE
RIEGELWOOD, COLUMBUS COUNTY, NORTH CAROLINA
OPERABLE UNIT 1
SEMS ID#: NCD991278631
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
SEPTEMBER 2017
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
PART 1: DECLAMATION
1J SITE NAME AND LOCATION
The LCP-Holtrachem Superfund Alternative Site (Holtrachem) is located near John Riegel Road in
Riegelwood. Columbus County, North Carolina. Honeywell International Inc. (Honeywell) is a
Potentially Responsible Party (PRP) that currently owns the site property. The site's identification
number in the Superfund Enterprise Management System (SEMS)1 is NCD991278631, The site consists
of only one Operable Unit (OU).
2.0 STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) selects the remedial action to address the contamination and risks posed
by the site. The remedy is selected in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) of I as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, and., to the extent practicable, the National Oil and Hazardous
Substances Contingency Plan (NOP). EPA based its decision on the Administrative Record for the site.
The State of North Carolina concurs with the selected remedy.
3.0 ASSESSMENT OF THE SITE
The response actions selected in this ROD are necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances into the environment.
4.0 DESCRIPTION OF SELECTED REMEDY
The remedial action selected in this ROD addresses contamination that poses unacceptable risks to
human, health and ecological receptors at the site. The wastes and contaminated media that poses
unacceptable risks include soil, sediment, surface water, mercury wastes and Wastewater Treatment
Solids (WWTS). The primary contaminants of concern are mercury and polychlorinated biphetiyls
(PCBs).
The selected remedy includes the following primary components:
Treatment of mercury waste and contaminated soil, considered, to be PTW, located beneath the
former mercury cell building and former retort pad via In-Situ Stabilization (ISS)
Capping of the areas treated by ISS in a maimer that meets Resource Conservation and Recovery
Act (RCRA) Subtitle C landfill final cover applicable or relevant and appropriate requirements
(ARARs)
Excavation of approximately 15,400 cubic yards (yd3) of contaminated soil and sediment
Capping approximately 1.7 acres of contaminated soil with a geosynthetic liner and vegetative
cover
1 In 2014, EPA replaced the Ccnprphens.vc- Environmental flp.-po iv Compensation and Liability Information System
(CERCLIS) database with SEIVSS 1 - > v ^ '
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Construction, operation, closure, maintenance and monitoring of an on-site disposal unit that
meets Toxic Substances Control Act (TSCA) chemical waste landfill ARARs in Title 40 Code of
Federal Regulations (CFR) § 761.75
Closure of the underground storm water conveyance system by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout
Disposal of stockpiled WWTS, solids removed from the storm water conveyance system, and
excavated contaminated soil and sediment that are not RCRA hazardous wastes in the
constructed on-site TSCA disposal unit
Treatment and/or disposal of RCRA hazardous wastes including soil that is considered RCRA
characteristic waste or contains RCRA listed waste, if generated, at an off-site permitted RCRA
treatment/disposal facility
Decommissioning of the storm water treatment system and restoration of the site to natural
drainage following completion of remedial action
Disposal or recycling of demolition debris from the stormwater treatment system and other
potentially dismantled structures. Disposition will be determined based on testing of the debris to
determine if it is RCRA hazardous wastes.
Monitoring and maintenance of the closed RCRA units (former surface impoundments) in
accordance with RCRA ARARs for post-closure care of a hazardous waste surface impoundment
Groundwater monitoring in accordance with ARARs to confirm TSCA disposal unit and closed
RCRA units' integrity
Engineering Controls (ECs) in the form of fencing, warning signs and erosion control measures
to control sedimentation from stormwater runoff
Implementation of Institutional Controls (ICs) in the form of a restrictive covenant and/or Notice
of Contaminated Site in accordance with North Carolina statute
Five-Year Reviews (FYRs)
5.0 STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are applicable or relevant and appropriate to the remedial action (unless justified by a
waiver), is cost-effective, and utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable. This remedy also satisfies the statutory
preference for treatment as a principal element of the remedy (i.e., reduces the toxicity, mobility, or
volume of hazardous substances, pollutants, or contaminants as a principal element through treatment).
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on-site
above levels that allow for unlimited use and unrestricted exposure, EPA will conduct statutory FYRs
beginning within five years after initiation of the remedial action to ensure that the remedy is protective
of human health and the environment.
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
6.0 DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information is located in the Administrative Record file for this site.
Item
Section Number
Chemicals of concern and their respective concentrations.
Section 5.6
Baseline risk represented by the chemicals of concern.
Section 7.0
Cleanup levels established for chemicals of concern and their basis
Section 12.4
How source materials constituting principal threats are addressed.
Section 11.0 and
Section 12.0
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
Potential land and groundwater use that will be available at the site
because of the Selected Remedy.
Section 12.4
Estimated capital, annual operation and maintenance (O&M), and total
present worth costs, discount rate, and the number of years over which the
remedy cost estimates are projected.
Section 9.3.3 and
Section 12.3
Key factors that led to selecting the remedy (i.e., describe how the Selected
Remedy provides the best balance of tradeoffs with respect to the
balancing and modifying criteria, highlighting criteria key to the decision).
Section 12.1 and
Section 13.0
7.0 AUTHORIZING SIGNATURE
This ROD documents the selection of the remedy for the LCP-Holtrachem Superfund Alternative Site.
The EPA selected this remedy with concurrence from the North Carolina Department of Environmental
Quality (NCDEQ).
Date
uperfund Division
U.S. Environmental Protection Agency, Region 4
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
TABLE OF CONTENTS
PART 1: DECLARATION
1.0 SITE NAME AND LOCATION
2.0 STATEMENT OF BASIS AND PURPOSE..
3.0 ASSESSMENT OF THE SITE
4.0 DESCRIPTION OF SELECTED REMEDY
5.0 STATUTORY DETERMINATIONS
6.0 DATA CERTIFICATION CHECKLIST iii
7.0 AUTHORIZING SIGNATURE iii
TABLE OF CONTENTS iv
ACRONYMS AND ABBREVIATIONS xiii
PART 2: THE DECISION SUMMARY 1
1.0 SITE NAME, LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
2.1 Ownership History 5
2.2 Operational History 5
2.3 Investigations, Actions and Violations under Authorities Other than CERCLA 9
2.3.1 OSHA 9
2.3.2 RCRA 9
2.3.3 Water Quality History 11
2.3.4 Air Quality History 12
2.4 CERCLA Investigations and Actions 13
2.4.1 CERCLA Investigations 13
2.4.2 CERCLA Emergency Responses and Removal Actions 13
2.4.3 CERCLA Enforcement Actions 18
3.0 COMMUNITY PARTICIPATION 18
4.0 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 19
5.0 SITE CHARACTERISTICS 20
5.1 Conceptual Site Model 20
5.2 Site Overview 21
5.3 Surface and Subsurface Features 25
5.3.1 Upland Process Area.... 25
53.2 Upland Non-Process Area 29
5.3.3 Wooded Bottomland Area 31
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LCP-Holtrachem Superfiind Site September 2017
5.4 Sampling Strategy 31
5.4.1 Surveys 31
5.4.2 Air 32
5.4.3 Surface Water and Sediment 33
5.4.4 Geology 35
5.4.5 Soil 35
5.4.6 Groundwater 39
5.5 Sources of Contamination 43
5.5.1 On-site 43
5.5.2 Off-site 44
5.6 Types of Contamination and Affected Media 45
5.6.1 Air 45
5.6.2 Surface Water 50
5.6.3 Sediment 68
5.6.4 Wastewater Treatment Solids 86
5.6.5 Soil 91
5.6.6 Groundwater 115
5.7 Location of Contamination and Routes of Migration 133
5.7.1 Location of Contamination 133
5.7.2 Potential Routes of Current and Future Migration 134
6.0 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 136
7.0 SUMMARY OF SITE RISKS 138
7.1 Human Health Risk Assessment 138
7.1.1 Identification of Chemicals of Concern 138
7.1.2 Exposure Assessment 139
7.1.3 Toxicity Assessment 140
7.1.4 Risk Characterization 140
7.1.5 Uncertainty Analysis : 142
7.2 Ecological Risk Assessment 143
7.2.1 Assessment Endpoints 143
7.2.2 Constituents of Potential Ecological Concern 143
7.23 Site Investigations in Support of the BERA 145
7.2.4 Exposure Analysis 147
7.2.5 Exposure Point Concentrations 147
7.2.6 Exposure Assumptions 148
7.2.7 Risk Characterization - Direct Exposure 148
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Record of Decision Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
7.2.8 Food Web Exposure - Terrestrial 151
7.2.9 Food Web Exposure - Aquatic 152
7.2.10 Other Food Web Exposure Constituents of Interest 153
7.2.11 Uncertainties 154
7.2.12 Conclusions 158
8.0 REMEDIAL ACTION OBJECTIVES 159
9.0 DESCRIPTION OF ALTERNATIVES 160
9.1 Description of Remedy Components 160
9.1.1 Alternative A-l: No Action 162
9.1.2 Alternative A-2: Capping with Limited Excavation, Off-site Disposal, and ICs/ECs 162
9.1.3 Alternative A-3: Combination of Capping and Excavation, On-site Disposal and ICs/ECs 166
9.1.4 Alternative A-4: Combination of Capping and Excavation, Off-site Disposal, and ICs/ECs 174
9.1.5 Alternative A-5: Excavation, On-site Disposal, and ICs/ECs 174
9.1.6 Alternative A-6: Excavation, Off-site Disposal, and ICs/ECs 177
Alternatives for soil in Retort Area and Cell Building Pad Area 178
9.1.7 Alternative S-l: No Action 178
9.1.8 Alternative S-2: Capping with Vertical Impermeable Barrier Installation and ICs 178
9.1.9 Alternative S-3: In-Situ Stabilization, Capping and ICs 181
9.1.10 Alternative S-4: Excavation and Off-site Treatment and Disposal 184
9.2 Applicable or Relevant and Appropriate Requirements (ARARs) 187
9.3 Common Elements and Distinguishing Features of Each Alternative 188
9.3.1 Components 188
9.3.2 Volumes 191
9.3.3 Costs and Timeframes 192
9.3.4 NCP Criteria 192
9.4 Expected Outcomes of Each Alternative 193
10.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 194
10.1 Overall Protection of Human Health and the Environment 196
10.1.1 A- Alternatives 197
10.1.2 S- Alternatives 197
10.2 Compliance with Applicable or Relevant and Appropriate Requirements 198
10.2.1 A-alternatives 200
10.2.2 S- alternatives 200
10.3 Long-Term Effectiveness and Permanence 200
103.1 A- alternatives 202
10.3.2 S- alternatives 202
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LCP-Holtrachem Superfund Site September 2017
10.4 Reduction of toxicity, mobility, or volume through treatment 203
10.4.1 A- alternatives 204
10.4.2 S- alternatives 205
10.5 Short-Term Effectiveness 206
10.5.1 A- alternatives 207
10.5.2 S- alternatives 208
10.6 Implementability 208
10.6.1 A-alternatives 209
10.6.2 S- alternatives 210
10.7 Costs 211
10.8 State Acceptance 212
10.9 Community Acceptance 212
10.10 Comparative Analysis Summary 212
10.10.1 A- alternatives 212
10.10.2 S- alternatives 213
11.0 PRINCIPAL THREAT WASTE 214
12.0 SELECTED REMEDY 215
12.1 Summary of the Rationale for the Selected Remedy 215
12.2 Description of the Selected Remedy 215
12.2.1 Wastes/Soils Beneath the Former Mercury Cell Building and Retort Pads 217
12.2.2 Overall Site Remedy 218
12.3 Summary of the Estimated Remedy Costs 224
12.3.1 Selected Remedy Alternative A-3 224
12.3.2 Selected Remedy Alternative S-3 228
12.4 Expected Outcome of the Selected Remedy 230
13.0 STATUTORY DETERMINATIONS 232
13.1 Protection of Human Health and the Environment 232
13.2 Compliance with ARARs 233
13.3 Cost Effectiveness 235
13.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable 235
13.5 Preference for Treatment as a Principal Element 235
13.6 Five-Year Review Requirements 236
14.0 DOCUMENTATION OF SIGNIFICANT CHANGES 236
PART 3: RESPONSIVENESS SUMMARY 237
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
APPENDICES
A APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS TABLES
Table A-l: Chemical-Specific ARARs and TBCs
Table A-2: Location-Specific ARARs and TBCs
Table A-3: Action-Specific ARARs and TBCs
B TRANSCRIPT FROM PROPOSED PLAN PUBLIC MEETING
LIST OF TABLES
Table 1: Removal Action #1 Waste Disposal Summary as of March 10, 2008 14
Table 2: List of Administrative Orders 18
Table 3: Above Ground Storage Tanks 29
Table 4: Surface Water Sampling Strategy Summary 2002-2009 33
Table 5: Sediment Sampling Strategy Summary 2002-2009 34
Table 6: Soil Sampling Strategy Summary 2002-2009 36
Table 7: Groundwater Monitoring Well Construction Informjation 39
Table 8: Groundwater Sampling Strategy Summary 42
Table 9: TIAS Data Summary for the Location with the Highest Average Concentration 48
Table 10: Vapor Intrusion Air Sample Results Summary 49
Table 11: Bottomland Drainage Ditch Surface Water Data Summary-Water Quality Parameters 50
Table 12: Bottomland Drainage Ditch Surface Water Data Summary - VOCs 51
Table 13: Bottomland Drainage Ditch Surface Water Data Summary-SVOCs 51
Table 14: Bottomland Drainage Ditch Surface Water Data Summary - Inorganics 52
Table 15: Bottomland Drainage Ditch Surface Water Data Summary - Pesticides 53
Table 16: Bottomland Drainage Ditch Surface Water Data Summary - PCBs 54
Table 17: Bottomland Drainage Ditch Surface Water Data Summary - Dioxins/Furans 56
Table 18: Bottomland Drainage Ditch Surface Water Data - Sample Results that Exceeded a PRG 57
Table 19: Bottomland Drainage Ditch Storm Water Data Summary - Water Quality Criteria 59
Table 20: Bottomland Drainage Ditch Storm Water Data Summary - SVOCs 60
Table 21: Bottomland Drainage Ditch Storm Water Data Summary - Inorganics 61
Table 22: Bottomland Drainage Ditch Storm Water Data Summary - Pesticides 62
Table 23: Bottomland Drainage Ditch Storm Water Data Summary - PCBs 62
Table 24: Bottomland Drainage Ditch Storm Water Data Summary - Dioxins/Furans 63
Table 25: Cape Fear River and Livingston Creek Surface Water Data Summary-Water Quality Parameters 65
Table 26: Cape Fear River and Livingston Creek Surface Water Data Summary - VOCs and SVOCs 65
Table 27: Cape Fear River and Livingston Creek Surface Water Data Summary - Inorganics 66
Table 28: Cape Fear River and Livingston Creek Surface Water Data Summary - Pesticides 67
Table 29: Cape Fear River and Livingston Creek Surface Water Data Summary - Aroclors and Dioxins/Furans .... 67
Table 30: Wooded Bottomland Drainage Pathway Sediment Data Summary - Characterization 69
Table 31: Wooded Bottomland Drainage Pathway Sediment Data Summary - VOCs 69
Table 32: Wooded Bottomland Drainage Pathway Sediment Data Summary - SVOCs 70
Table 33: Wooded Bottomland Drainage Pathway Sediment Data Summary - Inorganics 71
Table 34: Wooded Bottomland Drainage Pathway Sediment Data Summary - Pesticides 72
Table 35: Wooded Bottomland Drainage Pathway Sediment Data Summary - PCBs 73
Table 36: Wooded Bottomland Drainage Pathway Sediment Data Summary - Dioxins/Furans 75
Table 37: Storm Sewer Sediment Data Summary - VOCs 77
Table 38: Storm Sewer Sediment Data Summary - SVOCs 78
Table 39: Storm Sewer Sediment Data Summary - Inorganics 79
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Summary of Remedial Alternative Selection
September 2017
Table 40: Storm Sewer Sediment Data Summary - Pesticides 80
Table 41: Storm Sewer Sediment Data Summary - Aroclor 1268 80
Table 42: Cape Fear River and Livingston Creek Sediment Data Summary - Characterization 81
Table 43: Cape Fear River and Livingston Creek Sediment Data Summary - VOCs 81
Table 44: Cape Fear River and Livingston Creek Sediment Data Summary - SVOCs 82
Table 45: Cape Fear River and Livingston Creek Sediment Data Summary - Inorganics 83
Table 46: Cape Fear River and Livingston Creek Sediment Data Summary - Pesticides 84
Table 47: Cape Fear River and Livingston Creek Sediment Data Summary - Aroclor 1268 84
Table 48: Cape Fear River and Livingston Creek Sediment Data Summary - Dioxins/Furans 85
Table 49: WWTS Data Summary - VOCs 87
Table 50: WWTS Data Summary - SVOCs 88
Table 51: WWTS Data Summary - Inorganics 88
Table 52: WWTS Data Summary - Pesticides 89
Table 53: WWTS Data Summary - Dioxins and Furans 90
Table 54: Upland Area Soil Data Summary - VOCs 91
Table 55: Upland Area Soil Data Summary - SVOCs 92
Table 56: Upland Area Soil Data Summary - Inorganics 94
Table 57: Upland Area Soil Data Summary - Pesticides 95
Table 58: Upland Area Soil Data Summary - PCBs 96
Table 59: Upland Area Soil Data Summary - Dioxins/Furans 98
Table 60: Bottomland Area Soil Data Summary - Percent Solids and TOC 99
Table 61: Bottomland Area Soil Data Summary - VOCs 99
Table 62: Bottomland Area Soil Data Summary - SVOCs 100
Table 63: Bottomland Area Soil Data Summary - Inorganics 101
Table 64: Wooded Bottomland Surface Soil Sample Results that Exceed an Inorganic PRG 102
Table 65: Wooded Bottomland Soil Data Summary - Pesticides 104
Table 66: Wooded Bottomland Soil Data Summary - PCBs 105
Table 67: Wooded Bottomland Surface Soil Sample Results that Exceed a PCB PRG 105
Table 68: Bottomland Area Soil Data Summary - PCB congeners 107
Table 69: Bottomland Area Soil Data Summary - Dioxins/Furans 108
Table 70: Wooded Bottomland Area Soil Sample locations that Exceed a Dioxin PRG 109
Table 71: Background Soil Data Summary - Percent Solids, TOC, VOCs and SVOCs 110
Table 72: Background Soil Data Summary - Inorganics Ill
Table 73: Background Soil Data Summary - Pesticides and PCBs 112
Table 74: Background Soil Data Summary - Dioxins/Furans 113
Table 75: Detected Analytes in POC-1/POC-1R during January 1993 - December 2000 116
Table 76: Detected Analytes in POC-2/POC-2R during January 1993 - December 2003 116
Table 77: Detected Analytes in POC-3 during January 1993 - December 2003 117
Table 78: Summary of mercury in groundwater during August 1992 - December 2003 118
Table 79: Constituents with Results Greater than Drinking Water Standards in April 2002 Sampling Event 122
Table 80: Summary of Detected Constituents - 2004 Groundwater 124
Table 81: Summary of Detected Constituents - 2009 Groundwater 125
Table 82: Groundwater Data for Mercury and Aroclor 1268 in September 2012 132
Table 83: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Surface Soil
138
Table 84: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Subsurface
Soil 139
Table 85: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Surface
Water 139
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Summary of Remedial Alternative Selection
September 2017
Table 86: Lower Trophic Level Final Direct Toxicity COPECs 144
Table 87: List of Remedial Alternatives 160
Table 88: Remedial Area Description 161
Table 89: Alternatives A1-A6 Common Elements and Distinguishing Features 189
Table 90: Alternatives S1-S4 Common Elements and Distinguishing Features 190
Table 91: Volume Comparisons by Remedy Mode 191
Table 92: Estimated Cost and Timeframes 192
Table 93: Comparative Analysis Summary for A-l through A-6 195
Table 94: Comparative Analysis Summary for S-l through S-4 195
Table 95: Criteria 1 - Overall Protection Summary 196
Table 96: Criteria 2 - Compliance with ARARs Summary 199
Table 97: Criteria 3 - Long-Term Effectiveness and Permanence Summary 201
Table 98: Criteria 4 - Reduction of Toxicity, Mobility or Volume via Treatment Summary 204
Table 99: Criteria 5 - Short-term Effectiveness Summary 206
Table 100: Criteria 6 - Implementability Summary 209
Table 101: Criteria 7 - Cost Summary 211
Table 102: Alternative A-3 Cost Estimate Summary 226
Table 103: Alternative S-3 Cost Estimate Summary 229
Table 104: Upland Area Cleanup Levels 230
Table 105: Wooded Bottomland Area Cleanup Levels 231
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
LIST OF FIGURES
Figure 1: General Site Location 2
Figure 2: Site surrounded by International Paper and the Cape Fear River 3
Figure 3: Site Location Map with Property Boundaries 4
Figure 4: Site Aerial Photograph - circa 1965 6
Figure 5: Mercury Cell Process 7
Figure 6: Chlorine Plant Process 8
Figure 7: Google Earth photo from February 1993 with descriptions added 15
Figure 8: Google Earth aerial photo during the WWTS removal action (October 2008) 17
Figure 9: Conceptual Site Model 20
Figure 10: General Area Location Map 22
Figure 11: Wetland Delineation Map 23
Figure 12:100-year Flood Zone 24
Figure 13: Buildings Remaining On-site 26
Figure 14: Partially Dismantled Process Area 28
Figure 15: Upland Non-Process Areas (with some UPA features also shown) 30
Figure 16: Wooded Bottomland Area 31
Figure 17: HAS sample locations on date of highest concentrations 47
Figure 18: Locations where constituents in Wooded Bottomland Drainage ditch surface water exceed a Human
Health PRG 58
Figure 19: Location of storm water samples that had a concentration that exceeds a surface water PRG for at
least one COC 64
Figure 20: Surface water result for COCs in Cape Fear River and Livingston Creek 68
Figure 21: Wooded Bottomland Drainage Pathways Sediment Sample Locations 76
Figure 22: Concentrations exceeding PRGs in Bottomlands 103
Figure 23: Concentrations of Aroclor 1268 Exceeding PRG in Bottomlands 106
Figure 24: Background Samples Location Map 114
Figure 25: Monitoring Well Locations 115
Figure 26: Locations of wells 10AR, 11A and 13A 119
Figure 27: Graph of mercury concentrations over time from well 11A 120
Figure 28: Exceedances in groundwater from April 2002 sampling event 123
Figure 29: Mercury in Groundwater 2004, 2009 and 2012 126
Figure 30: Aroclor 1268 in Groundwater 2004, 2009 and 2012 .127
Figure 31: Pesticides in Groundwater 2004 & 2009 128
Figure 32: Metals in Groundwater 2004 & 2009 129
Figure 33: SVOCs in Groundwater 2004 & 2009 130
Figure 34: Location of P9 and Observed Intermittent Seep Area 131
Figure 35: Remedial Footprint 133
Figure 36: Columbus County Zoning 137
Figure 37: BERA Sampling Locations 146
Figure 38: Alternative A-2 Conceptual Remedial Plan 163
Figure 39: Alternatives A-3 and A-4 Conceptual Remedial Plan 166
Figure 40: On-site Conceptual TSCA Disposal Unit Cross-Section 171
Figure 41: On-site TSCA Disposal Unit Conceptual Layout 172
Figure 42: Alternatives A-5 and A-6 175
Figure 43: Alternative S-2 179
Figure 44: Alternative S-3 182
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Summary of Remedial Alternative Selection
September 2017
Figure 45: Alternative S-4 185
Figure 46: Remedial Footprint 216
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ACRONYMS AND ABBREVIATIONS
2L Title 15A North Carolina Administrative Code Subchapter 2L Groundwater Standards (I5A
NCAC2L Standard)
ACM asbestos-containing material
AMECFW AMEC Foster Wheeler Environment & Infrastructure, Inc.
AOC Administrative Order on Consent
App. Gamma Approximate Gamma
AR Administrative Record
ARAR Applicable or Relevant and Appropriate Requirements
AST above ground storage tank
AUF area use factor
BAF bioaccumulation factor
BERA Baseline Ecological Risk Assessment
BG background
BPT Bleach Plant
CBP Cell Building Pad
CCC criterion continuous concentration
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation and Liability Information System
CFR Code of Federal Regulations
Cheb Chebyshev Minimum Variance Unbiased Estimate of Upper Confidence Limit
Cheb-m Chebyshev (mean, standard deviation) Uper Confidence Limit
cm/s centimeter per second
COC Chemical of Concern
COPC Chemical of Potential Concern
COPEC contaminant of potential ecological concern
CSF cancer slope factor
CSM Conceptual Site Model
CTA CTA Environmental, Inc.
CTE central tendency exposure
DDT dichloro-diphenyltrichloroethane
DPT direct push technology
DQO data quality objective
DWQ Division of Water Quality
EC Engineering Control
ECBPA East Cell Building Pad Area
EE/CA Engineering Evaluation / Cost Analysis
EPA U.S. Environmental Protection Agency
EPC Exposure Point Concentration
EPDM ethylene propylene diene-monomer
ERRB Emergency Response and Removal Branch
ESI/RA Expanded Site Inspection and Removal Assessment
ESP Engineered Stockpile
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Summary of Remedial Alternative Selection
September 2017
ESV ecological screening value
FEMA Federal Emergency Management Agency
FIL Fill Area
FS Feasibility Study
ft2 square feet
ft amsl feet above mean sea level
ft bgs feet below ground surface
ft/yr feet per year
FYR Five-Year Review
GPS Global Positioning System
HCI hydrochloric acid
HDPE high density polyethylene
HEAST Human Effects Assessment Summary Tables
Hg mercury
HHRA Human Health Risk Assessment
HI hazard index
Honeywell Honeywell International Inc.
HQ hazard quotient
IC Institutional Control
iESI/RA Integrated Expanded Site Inspection / Removal Assessment
IP International Paper
IRIS Integrated Risk Information System
ISS In-Situ Stabilization
IVMP Inspection and Vapor Monitoring Plan
Kow octanol: water distribution coefficient
LC50 50 percent mortality
LCP Linden Chemicals & Plastics, Inc.
LEL lower effects level
LLTW Low Level Threat Waste
LOAEL Lowest Observed Adverse Effects Level
LOEC lowest observed effect concentration
LTTD low temperature thermal destruction
MCL Maximum Contaminant Level
MESS Mercury Elimination Sewer System
mg/kg milligram per kilogram
mg/L milligram per liter
MNAF mercury not accounted for
MW monitoring well
N/A not applicable
NAVD 88 North American Vertical Datum of 1988
NAWQC National Ambient Water Quality Criteria
NC North Carolina
NCBPA North Cell Building Pad Area
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Summary of Remedial Alternative Selection
September 2017
NCDENR
North Carolina Department of Environment and Natural Resources
NCDEQ
North Carolina Department of Environmental Quality
NCEA
National Center for Environmental Assessment
NCP
National Oil and Hazardous Substances Contingency Plan
ng/L
nanogram per liter
NGVD29
National Geodetic Vertical Datum of 1929
NOAEL
No Observed Adverse Effects Level
NOV
Notice of Violation
NPDES
National Pollutant Discharge Elimination System
NRB
North Retention Basin
NRWQC
National Recommended Water Quality Criteria
NUS
NUS Corporation
O&M
Operation and Maintenance
OA
Office Area
ONP
Old North Pond
OPA
Old Parking Area
OSC
On-Scene Coordinator
OSD
Old Salt Dock area
OSHA
Occupational Safety and Health Administration
OSP
Old South Pond
OU
Operable Unit
PA
Preliminary Assessment
PCB
polychlorinated biphenyl
Pg/L
picograms per liter
POC
point of compliance
POLREP
pollution report
PPBV
parts per billion volume
PPm
part per million
PPR7V
Provisional Peer-Reviewed Threshold Value
PRG
preliminary remediation goal
PRD
Products Area
Premier
Premier Environmental Services, Inc.
PRP
Potentially Responsible Party
PTW
Principal Threat Waste
PVC
polyvinyl chloride
QA/QC
quality assurance/quality control
RAGS
Risk Assessment Guidance for Superfund
RAL
Removal Action Level
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
RET
Retort area
RfD
reference dose
Rl
Remedial Investigation
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RLS registered land surveyors
RME reasonable maximum exposure
ROD Record of Decision
RP Roberts Pond
RSL Regional Screening Value
RYD Rail Yard Area
SARA Superfund Amendments and Reauthorization Act
SCBPA South Cell Building Pad Area
SEMS Superfund Enterprise Management System
Site LCP-Holtrachem Superfund Site
SLERA Screening-Level Ecological Risk Assessment
SMCL Secondary Maximum Contaminant Level
SPLP synthetic precipitation leaching procedure
SRB South Retention Basin
SS Sewer System
SVOC semi-volatile organic compound
SW surface water
SWDS Solid Waste Disposal Site
SWMU Solid Waste Management Unit
TAL Target Analyte List
TBC to be considered
TCDD Tetrachlorodibenzo-p-Dioxin
TCL Target Compound List
TCLP Toxicity Characteristic Leaching Procedure
TEF toxicity equivalent factor
TEQ toxicity equivalent quotient
TIAS Time Integrated Air Sampling
TIMVS time-integrated mercury vapor sampling
TOC total organic carbon
TRV Toxicity Reference Value
TSCA Toxic Substances Control Act
TSS total suspended solid
UCL upper confidence limit
UNPA Upland Non-Process Area
UPA Upland Process Area
URL Uniform Resource Locator
US United States
USGS United States Geological Survey
Hg/L microgram per liter
|ig/m3 microgram per cubic meter
VI vapor intrusion
VOC volatile organic compound
WBA Wooded Bottomland Area
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WCBPA West Cell Building Pad Area
Weston Weston Solutions, Inc.
WHO World Health Organization
WOE weight of evidence
WWT Wastewater Treatment
WWTS Wastewater Treatment Solids
yd3 cubic yard
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PART 2: THE DECISION SUMMARY
The EPA prepared this ROD using information from documents in the Administrative Record, websites, and
EPA guidance documents.
1.0 SITE NAME, LOCATION AND DESCRIPTION
The LCP-Holtrachem site (the site) is located at 636 John L. Riegel Road in Riegelwood, Columbus
County, North Carolina. Riegelwood is about 20 miles west-northwest of Wilmington, North Carolina.
The site consists of about 24.4 acres. The International Paper (IP) Riegelwood Mill facility surrounds
the site on three sides and the Cape Fear River borders the fourth side. IP is an industrial pulp and paper
manufacturing facility that opened in 1951 and occupies about 1,300 acres surrounding the site. The
Cape Fear River is approximately 200 miles long and flows to the Atlantic Ocean. Near the site, the
tidally influenced Cape Fear River is over 300 feet wide and up to 26 feet deep. Figure 1 illustrates the
general location of the site. Figure 2 is an aerial view of the site and surrounding properties. Figure 3
shows the property boundaries for the site and IP.
The site's identification number in the SEMS is NCD991278631. EPA is the lead agency for the site and
the NCDEQ2 is the support agency. The PRP, Honeywell, plans to implement the selected remedy with
EPA and NCDEQ oversight.
In 1963, Allied Chemical Corporation developed the Holtrachem site as an industrial chlor-alkali
manufacturing facility. Property ownership changed several times until the plant closed in November
2000. During operations, the facility produced various chemicals using a mercury electrolytic cell
process. These chemicals included caustic liquid (sodium hydroxide), liquid chlorine, hydrogen gas,
liquid bleach (sodium hypochlorite), and hydrochloric acid. The primary contaminants at the site are
mercury and the polychlorinated biphenyl (PCB) known as Aroclor 1268. Both of these are hazardous to
human health and the environment and were components of the mercury electrolytic cell process.
2 On September 18, 2015, the North Carolina Department of Environment and Natural Resources (NCDENR)'s name
changed to the North Carolina Department of Environmental Quality (NCDEQ). http://portal.ncdenr.org/web/guest/denr-
bloe/-/blogs/denr-has-a-new-name-n-c-dept-of-environmental-aualitv? 33 redirect=%2Fweb%2Fguest%2Fdenr-blog
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Figure 1: General Site Location
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Figure 2: Site surrounded by International Paper and the Cape Fear River
Summary of Remedial Alternative Selection
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Figure 3: Site Location Map with Property Boundaries
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Ownership History
On August 15, 1963, Riegel Paper Corporation transferred 26.26 acres of their property to Allied
Chemical Corporation, most of which consists of the current LCP-Holtrachem site. Prior to that, aerial
photographs show the property as an undeveloped wooded area. In 1985, the facility transferred back
approximately two acres to Federal Paperboard Company, Inc. (formerly Riegel Paper Corporation and
now known as International Paper Riegelwood Mill). Therefore, the site property is currently about 24.4
acres.
Ownership of the site property changed numerous times. Owners included Allied Chemical Corporation,
LCP Chemicals - North Carolina, Hanlin Group, Inc., Holtrachem Manufacturing Company, LLC, and
currently Honeywell.
2.2 Operational History
The site consisted of a chlor-alkali manufacturing facility from 1963 until 2000. Figure 4 illustrates an
aerial view of a portion of the plant in about 1965. The facility produced various chemicals using a
mercury electrolytic cell process. These chemicals included caustic liquid (sodium hydroxide), liquid
chlorine, hydrogen gas, liquid bleach (sodium hypochlorite), and hydrochloric acid. The facility
transferred most of the caustic, chlorine, bleach, and hydrogen that it produced to the adjacent IP plant
by pipeline. The facility sold the remaining chlorine, caustic, and acid to other companies. These
products were transported by railcars and tanker trucks for distribution. The mercury cell operation shut
down in April 1999, and the entire plant closed in November 2000. The mercury cell and chlorine
processes are illustrated in Figure 5 and Figure 6, respectively.
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Figure 4: Site Aerial Photograph - circa 1965
-> Suspec
Discharg
Holtrachem Property
. Likoly PCB
- Imgregnation
Bottomlands
Head of Central
Orainage Pathway
Illustration 1-3: Site Aerial Photograph - circa 1965
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Figure 5: Mercury Cell Process
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Figure 6: Chlorine Plant Process
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23 Investigations, Actions and Violations under Authorities Other than CERCLA
While in operation, environmental evaluations at the facility focused on compliance with RCRA and the
Occupational Safety and Health Administration (OSHA) regulations. Corrective action activities also
occurred pursuant to the RCRA operating permit issued by NCDENR. A summary of the primary
evaluations, actions and cited violations follow.
2.3.1 OSHA
In 1996, OSHA fined the facility $31,854 for an inadequate health and safety program. In December
1998, OSHA fined the facility $873,000, for failure to correct problems noted in 1996. OSHA reduced
the fine to $100,000 after the plant's operator said the problems had been corrected.
2.3.2 RCRA
The facility operated under a RCRA Hazardous Waste permit. NCDENR issued permit number
NCD991278631 to the facility on December 29, 1989. The permit became effective on June 28,1991.
The permit was modified on May 2, 1994, due to a change in the facility's ownership and operational
control. In January 2002, after the facility ceased operations, NCDEQ RCRA Program referred the site
to the Superfund program for further evaluation and remedial action under CERCLA.
2.3.2.1 Closed Surface Impoundments
Former facility operations included the creation and use of four surface impoundments: Solid Waste
Disposal Site (SWDS), Roberts Pond, North Pond, and South Pond. The facility used these
impoundments to treat and contain wastes generated during plant processes.
The SWDS, also known as the Allied Vault, received wastes including graphite anodes, stems, sludge,
fly ash, concrete, sodium chloride, activated carbon, filter aid media, and mercury sludge generated from
1963 to 1980. The bottom liner of the SWDS included two feet of clay overlain by a polyvinyl chloride
(PVC) liner overlain by another two feet of clay. The top cover of the SWDS consisted of a four-foot
thick layer consisting of clay, marl, and asphalt. In 1985, the facility closed the SWDS with
approximately 3,700 yd3 of solidified wastes in place and capped with an asphalt cover graded to
promote runoff toward the wooded bottomland area.
The Old South Pbnd was an ethylene propylene diene-monomer (EPDM) rubber lined surface
impoundment that held about 1.06 million gallons of process wastewater and sludge. The Old North
Pond had a PVC liner and functioned as an overflow basin with a capacity of 1.71 million gallons. These
ponds received mercury-contaminated brine processing wastewater and sludge.
In the early 1970s, the facility constructed Roberts Pond. It was originally unlined and received
mercury-contaminated wastes from the brine processing. In 1979, the facility installed a rubber liner.
Site drawings from the late 1970s indicate a second pond (the old salt brine pit), to the west of Roberts
Pond, was used to contain overflow from Roberts Pond. This second pond was reportedly backfilled and
the area later used for salt storage prior to the construction of the membrane building.
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In the 1980s, the facility closed Roberts Pond, the Old North Pond and the Old South Pond. Closure
involved removal of materials from Roberts Pond and the Old North Pond, stabilization of the material
with fly ash and dry cement, and placement into the Old South Pond. The PVC liners from Roberts Pond
and the Old North Pond were sealed together, placed over the stabilized sludge, then bonded to the
EPDM base liner and anchored in a trench. A compacted clay cap was then placed over the PVC liner to
complete the closure of the South Pond.
Neither Roberts Pond nor the Old North Pond received official clean closure status under RCRA. The
facility conducted groundwater monitoring for compliance purposes in general accordance with the post-
closure care provisions set forth in the Hazardous Waste Management Part B Permit Application and the
Hazardous Waste Management Permit, which became effective June 28, 1991.
2.3.2.2 RCRA Hazardous Waste
The facility operations generated four hazardous wastes identified as D009, F003, F005, and K106.
D009 is a solid waste that exhibits the characteristic of toxicity due to hazardous concentrations of
mercury as defined in 40 CFR §261.24. The facility used a retort thermal reclamation process for
mercury-contaminated solids. The residual ash created in this process was classified as D009 hazardous
waste.
F003 and F005 are hazardous wastes from non-specific sources. They are defined in 40 CFR §261.31 as
follows:
F003: The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl
benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all
spent solvent mixtures/blends containing, before use, only the above spent nonhalogenated
solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above
nonhalogenated solvents, and a total of ten percent or more (by volume) of one or more of those
solvents listed in FOOl, F002, F004, and F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
F005: The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbon
disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent
mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more
of the above nonhalogenated solvents or those solvents listed in F001, F002, or F004; and still
bottoms from the recovery of these spent solvents and spent solvent mixtures.
K106 is a hazardous waste from a specific source. It is defined in 40 CFR §261.32 as, " Wastewater
treatment sludge from the mercury cell process in chlorine production." The facility generates K106
hazardous waste through its wastewater pretreatment system called the Mercury Elimination Sewer
System (MESS). Wastewater is initially treated through the MESS to adjust pH, then sodium sulfide is
added to form a mercury sulfide precipitate in a settling tank/clarifier. The settled mercury sulfide sludge
is pumped to a filter press. The filter cake is stored and subsequently shipped off-site as a hazardous
waste (K106).
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2.3.2.3 RCRA Violations and Corrective Actions
A review of historical records indicated that between 1989 and 2001, there were five documented RCRA
violations at the facility. These include:
December 1989 - NCDENR issued a Notice of Violation (NOV) for
o failure to use the correct hazardous waste code of K106 for disposal of the wastewater
treatment sludge from the mercury cell process, and
o failure to provide proper documentation of disposal.
February 1996 - NCDENR issued a NOV for violations noted in a January 1995 inspection. The
violations included:
o a waste pile at the MESS,
o unlabeled waste,
o mercury waste accumulation of greater than 90 days,
o leaking wastewater treatment tank,
o employee training out of compliance, and
o uncovered vat and floor sweepings at the MESS, which were unlabeled and not dated.
May 2000 - NCDENR issued an Order for
o failure to demonstrate clean closure equivalency of Robert's Pond and
o plans to construct a building over Robert's Pond without agency approval.
September 2000 - NCDENR required maintenance of the cap on the retort pad and removal of
nearby debris.
October 2001 - NCDENR issued an Imminent Hazard NOV for
o failure to characterize waste,
o failure to properly contain waste, and
o accumulation of waste for greater than 90 days.
2.3.3 Water Quality History
From 1963 to 1978, spill containment and storm water management appear to be minimal at the site.
The first documented release of hazardous substances to the adjacent Cape Fear river was in August
1978. This event involved a spill of approximately 400 gallons of brine solution that flowed into the
river. The concentration of mercury in the brine solution was 3.6 milligrams per liter (mg/L).
Afterwards, the facility constructed a water management system that would prevent discharges to
surface waters. By 1979, the facility had begun transferring wastewater collected by the water
management system to IP's wastewater treatment system. Initially, the transfer was via an open ditch. In
October 1989, a NCDENR inspection noted that water transference was by pipe instead of the open
ditch.
In November 1993, a NCDENR inspection found mercury at a concentration of 0.035 mg/L in IP's
discharge water. By 1999, mercury was a compliance issue for IP. Holtrachem and IP reached an
agreement for reducing mercury contributions from products supplied by Holtrachem, and these
provisions were included in IP's National Pollutant Discharge Elimination System (NPDES) Permit.
In April 1999, approximately 1,800 gallons of wastewater was unintentionally released. The
concentrations of mercury in soil samples ranged from 1.96 to 13.7 milligrams per kilogram (mg/kg).
The facility shut down the mercury cell operation two days later.
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In May 1999, approximately 18,000 gallons of wastewater spilled from a storm water retention basin.
The concentration of mercury in the water was 0.34 mg/L.
In September 1999, Hurricane Floyd caused a release of about 2.2 million gallons of storm water to the
Cape Fear River. This event released about 5 pounds of mercury over a 19-hour period.
In October 1999, NCDENR issued a NOV and Assessment of Civil Penalty to the facility based on a
review of the July 1999 discharge monitoring report. The violation was for exceeding permitted monthly
average effluent limits for settleable solids.
2.3.4 Air Quality History
Air emissions history prior to 1979 is not documented. Beginning in the 1980s, Holtrachem operated
under an air permit and provided annual air emissions inventory.
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2.4 CERCLA Investigations and Actions
2.4.1 CERCLA Investigations
The "Discovery" date listed in SEMS is November 1, 1979. Two dates are currently in SEMS for
Preliminary Assessments (PA): August 1, 1982 and November 2, 1987. The PA form located in the
references of the integrated Expanded Site Inspection/Removal Assessment (iESI/RA) report is dated
September 11, 1987.
On January 11, 2002, NCDENR sent a referral letter to EPA's Emergency Response and Removal
Branch (ERRB). An EPA On-Scene Coordinator (OSC) visited the site on January 30, 2002, and
February 20, 2002. In April 2002, EPA's contractor Weston Solutions, Inc. (Weston) conducted an
iESI/RA in conjunction with NCDENR. Based on the findings of these inspections, EPA authorized a
removal action.
In June 2004, Honeywell initiated an Engineering Evaluation/Cost Analysis (EE/CA) study with EPA
oversight. Honeywell's contractors collected samples of air, surface water, groundwater, sediment, soil
and biota. After Honeywell submitted the draft EE/CA report, EPA determined that it would be more
appropriate to address the remaining contamination under remedial instead of removal authority. In
September 2009, EPA converted the project from an EE/CA into a Remedial Investigation/Feasibility
Study (RI/FS). EPA approved the Remedial Investigation (RI) report on July 29, 2014.
2.4.2 CERCLA Emergency Responses and Removal Actions
Two CERCLA emergency responses and two CERCLA removal actions have occurred. These include:
1999: Hurricane Floyd Emergency Response
2003-2004: Removal Action #1
2003: Hurricane Isabel Emergency Response
2008-2009: Removal Action #2 (IP Removal Action)
The PRP's contractors participated in all of these events. EPA provided contractor support during the
two emergency responses and provided oversight activities during all events. A brief summary of each
event is described in Sections 2.4.2.1 - 2.4.2.4.
2.4.2.1 Hurricane Floyd Emergency Response (1999)
In September 1999, Hurricane Floyd inundated the site with an estimated 24-inches of rain. The
associated flooding caused a release of contaminated water from a storm water retention basin. The
release flowed over land into the adjacent Cape Fear River. EPA and the Federal Emergency
Management Agency (FEMA) responded. EPA personnel and contractors assisted facility personnel in
sand-bagging to raise the berm height of the storm water collection basin and pumping water to IP.
2.4.2.2 Removal Action #1 (2002-2004)
i
In July 2002, EPA signed an Enforcement Action Memorandum for a time-critical removal action. EPA
and Honeywell entered into an Administrative Order on Consent (AOC) for this removal action. The
removal action began in January 2003. EPA issued the Final Pollution Report (POLREP) in October
Summary of Remedial Alternative Selection
September 2017
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2004, marking the completion of the removal action. During the removal action, workers dismantled the
former mercury cell building and associated piping, encapsulated mercury-contaminated debris prior to
off-site shipment/disposal, and collected over 34,000 pounds of mercury for reclamation/reuse. Workers
also dismantled/disposed of other RCRA hazardous waste and non-hazardous waste/debris associated
with some of the former facility operations. Southern Metal Recycling accepted over 1.5 million pounds
of scrap metal, copper, aluminum, brass, titanium and stainless steel from the site for recycling. Table 1
summarizes of the types of waste, disposition and quantities that were transported off-site associated
with the removal action through March 2008.
Table 1: Removal Action ttl Waste Disposal Summary as of March 10, 2008
Disposition
Facility
Waste Stream
Quantity Shipped
Off-site
Reuse
Goldsmith
Evanston, IL
Reclaimed Elemental Mercury
(for Reuse)
34,447 pounds
Recycling
Southern Metals Recycling
Wilmington, NC
Scrap Metal
1,317,529 pounds
Scrap Copper
183,177 pounds
Scrap Aluminum
20,250 pounds
Scrap Stainless Steel
14,650 pounds
Scrap Titanium
4,280 pounds
Scrap Brass
1,232 pounds
Hazardous
Waste
Waste Management
Emelle Treatment Facility
Emelle, AL
Saturator Salt
1,008,180 pounds
Hazardous - Variance Debris
761,972 pounds
Hazardous - Macro (including
hazardous asbestos-
containing material (ACM))
99 boxes
Non-Regulated Material -
Directly Landfilled
80 boxes
Hazardous - Micro
47 boxes
EQ- Michigan Disposal Waste
Treatment
Belleville, Ml
D009 - Wastewater Filter Cake
24 boxes
Non-
Hazardous
Waste
Anson Waste Management Facility
Polkton, NC
Non-Hazardous ACM
22,040 pounds
Sampson Co. Disposal Facility
Roseboro, NC
Non-Hazardous Construction
Debris
676,260 pounds
Notes:
ACM = asbestos-containing material
boxes = box sizes ranged from 20 to 30 yd3
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2.4.2.3 Hurricane Isabel Emergency Response (2003)
In September 2003, EPA signed an Emergency Response Action Memorandum to assist the facility with
preparations for and responding to potential impacts from Hurricane Isabel. Activities included
stabilization of tarps on roll-off boxes, movement of hazardous substance drums into warehouses, and
strapping down loose items. Hurricane Isabel passed through the area on September 17, 2003. The
PRP's contractor handled all water and reported that only minor damage occurred to the cell building
metal sheeting. EPA contractors demobilized from the site on September 19, 2003.
2.4.2.4 Removal Action #2 (2008-2009)
In the early 2000s, IP planned to expand their landfill capacity by taking out of service one of their
former wastewater treatment lagoons. Figure 7 shows the lagoon that historically accepted wastewaters
from the Holtrachem facility.
Figure 7: Google Earth photo from February 1993 with descriptions added
In September 2005, IP contracted with Premier Environmental Services, Inc. (Premier) to characterize
the Landfill Cell No. 2 area. IP shared the results with EPA. The findings led to EPA issuing an
Enforcement Action Memorandum and entering into an AOC with Honeywell and IP for the removal of
WWTS containing PCBs. PCB concentrations equal to or greater than 50 mg/kg (or 50 ppm) are
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regulated for disposal as TSCA PCB waste and must be managed in accordance with TSCA regulations
at 40 CFR 761 et. seq.
During 2008-2009, contractors performed the following activities:
Construction of two engineered stockpiles on the Holtrachem property.
Excavation and transportation of WWTS containing Aroclor 1268 at concentrations equal to or
greater than 50 mg/kg from IP Landfill Cell No. 2 to the engineered stockpiles.
Excavation and transportation of WWTS containing Aroclor 1268 at concentrations less than 50
mg/kg from IP Landfill Cell No. 2 to IP Landfill Cell No. 1.
Removal of piping that reportedly transported wastewater from the Holtrachem facility to
Landfill Cell No. 2 and associated impacted soil containing Aroclor 1268.
Management of wastewater generated during the removal activities, including chemical
treatment (using a flocculant and coagulant) prior to collection of water in two settling ponds;
bag filtration; carbon filtration; and routine sampling to ensure that Aroclor 1268 concentrations
were less than 3 micrograms per liter (|ig/L) prior to discharge to IP's wastewater treatment
system.
Collection of confirmation samples to confirm achievement of cleanup goals.
Collection of samples at a rate of approximately one per 1,000 yd3 of material placed in the
engineered stockpiles. An off-site laboratory analyzed the 19 samples for Volatile Organic
Compounds (VOCs), Semi-Volatile Organic Compounds (SVOCs), metals, pesticides and
dioxins.
Approximately 22,500 yd3 of WWTS containing Aroclor 1268 at concentrations equal to or greater than
50 mg/kg were excavated and transported from IP Cell No. 2 and placed in the engineered stockpiles.
Approximately 70,500 yd3 of WWTS containing Aroclor 1268 at concentrations less than 50 mg/kg
were excavated and transported from IP Cell No. 2 to IP Landfill Cell No. 1. More than 6.5 million
gallons of water was pre-treated and discharged to IP's wastewater treatment system during the removal
activities. Figure 8 is a Google Earth aerial photograph from October 2008 that shows the removal
action work in progress.
Honeywell's consultant incorporated weekly inspections of the engineered stockpiles into the pre-
existing Post Removal Site Control Plan. Typically, wastes with concentrations of PCBs greater than or
equal to 50 mg/kg are regulated for disposal as TSCA PCB waste and are disposed of in a TSCA
chemical waste landfill. The engineered stockpiles were planned as temporary storage. The disposition
of this waste material is included as part of the remedy selected in this ROD.
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Figure 8: Google Earth aerial photo during the WWTS removal action (October 2008)
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2.4.3 CERCLA Enforcement Actions
In April 2002, EPA sent a General Notice Letter to Honeywell. To date, EPA and Honeywell have
entered into the four administrative orders listed in Table 2. IP is also a party in one of them. The PRPs
have paid oversight bills in a timely manner. Informal discussions with Honeywell indicate that they will
agree to implement the remedy selected in this ROD.
Table 2: List of Administrative Orders
Acronym
Title
Docket#
Parties Involved
Effective
Date
AOC1
Administrative Order on Consent for Removal Action
CER-04-2002-3771
EPA
7/1/2002
Honeywell International Inc.
AOC2
Administrative Order on Consent for Removal Action
CER-04-2004-3781
EPA
7/8/2004
Honeywell International Inc.
AOC3
Administrative Settlement Agreement and Orderon
Consent for Removal Action
CERCLA-04-2008-3769
EPA
5/20/2008
Honeywell International Inc.
International Paper Company
AOC4
Administrative Settlement Agreement and Orderon
Consent for Remedial Investigation/Feasibility Study
CERCLA-04-2009-3980
EPA
9/15/2009
Honeywell International Inc.
3.0 COMMUNITY PARTICIPATION
In accordance with Section 300.430(f)(3) of the NCP, the EPA performed community participation
activities related to selecting the cleanup action described in this ROD. EPA updated the Administrative
Record (AR) for the site by adding documents that EPA used in selecting the cleanup plan. These
documents include, among others, the Community Involvement Plan, RI Report, Ecological Risk
Assessment, Baseline Human Health Risk Assessment, Feasibility Study (FS) and Proposed Plan.
EPA maintains the AR file at the EPA Region 4 office and at the East Columbus Public Library. EPA
published a notice of the availability of these documents in the Star News on August 15, 2016. EPA held
a public comment period from August 15, 2016 to September 14, 2016. In addition, EPA hosted a public
meeting on August 23, 2016, at Riegelwood Community Center, in Riegelwood, NC to present the
Proposed Plan to community members. At this meeting, representatives from EPA, NCDEQ, Honeywell
and AMEC Foster Wheeler Environment & Infrastructure, Inc. (AMECFW) answered questions about
the site and the remedial alternatives. A transcript of the meeting and EPA's response to comments
received during the public comment period is included in this ROD in Part 3, the Responsiveness
Summary. EPA did not receive any written comments from community members on the Proposed Plan.
Just prior to the start of the public meeting, NCDEQ verbally informed EPA and the PRP that some of
their approved language changes on the draft FS were not included in the July 2015 version. The PRP's
consultant acknowledged the oversight and submitted a revised FS on September 7, 2016. EPA and
NCDEQ have approved the September 2016 FS and EPA has added it to the AR.
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4.0 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Under EPA oversight, the PRPs previously conducted two removal actions at the site. The first removal
action addressed the immediate threats of spilled and containerized wastes. As described in Section
2.4.2, Honeywell's contractors dismantled the former cell building and associated structures and
transported wastes to off-site disposal facilities. In the second removal action, the PRPs contractors
excavated WWTS from the adjacent IP property and transported WWTS that contained concentrations
of Aroclor 1268 above 50 mg/kg to the site. The WWTS is sealed inside two engineered stockpiles.
EPA is selecting the final remedy for the site and the remedial action is under one OU. The remedial
action selected in this ROD addresses the following contaminated media and wastes: soil, sediment,
surface water, former RCRA units, mercury wastes and the on-site stored WWTS. The response actions
for the selected remedy include a variety of components that are described in Sections 9.1.3 and 9.1.9.
Groundwater contamination is limited to the uppermost aquifer unit, which has insufficient yield for
drinking water use. Based on multiple criteria, the aquifer is characterized as an EPA Class III, Subclass
III A, not suitable as a potential source of drinking water and of limited beneficial use per "Guidelines
for Ground-Water Classification Under the EPA Groundwater Protection Strategy", and the human
health and ecological pathways for exposure to contaminated groundwater are incomplete. Data
indicates that detected constituents in groundwater are not migrating and are not causing detriment to
human health or the environment.
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5.0 SITE CHARACTERISTICS
5.1 Conceptual Site Model
The Conceptual Site Model (CSM) is illustrated in Figure 9. Historical manufacturing operations
resulted in the release of contaminants into the environment. The primary sources of contamination are
from the historical mercury cell operations, retort operations, Aroclor 1268 graphite impregnation
operations, spills and leaks. These operations and releases resulted in contaminated soil, sediment and
surface water by overland flow (i.e., stormwater runoff) and atmospheric deposition.
Figure 9: Conceptual Site Model
Summary of Remedial Alternative Selection
September 2017
Surface drainage direction
Mercury and/or Aroclor 12E8
Contamination areas
LCP-Holtrachem
(Not to Scale)
Conceptual Site Model
Riegelwood, North Carolina
amacl
fbstarl
Figure
Number
1-4
North
(Overland Runoff
Surficial Deposits
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.2 Site Overview
The site is approximately 24.4 acres. It is surrounded by IP on all sides, except where the site borders the
Cape Fear River. The site is generally lower in elevation than the adjacent IP property (in some areas by
10 to 15 feet). The site was divided into three areas for purposes of the risk assessments. The areas are
illustrated in Figure 10.
The Upland Process Area (UP A) is approximately 11.8 acres and consists of the former process and
operational areas, and the wastewater treatment area. The majority of the UPA is relatively flat with
ground surface elevations ranging from approximately 35 to 36 feet using the North American Vertical
Datum of 1988 (NAVD 88). The eastern portion of the UPA slopes to the east with elevations ranging
from 29 to 35 feet.
The Upland Non-Process Area (UNPA) is approximately 4.2 acres located in the east central portion of
the site. This area contains two surface impoundments referred to as the Old North Pond and the Old
South Pond, and two (north and south) retention basins surrounded by grassed areas.
The Wooded Bottomland Area (WBA) is approximately 8.4 acres located along the northern and eastern
boundaries of the site. It consists of 7.3 acres of delineated wetlands, which are illustrated in Figure 11.
This area is located within an alluvial floodplain between the Cape Fear River and the industrialized
portions of the site. In general, the land slopes to the northeast, as the western half of the bottomland
forest is higher than the eastern half with elevations ranging from 10 to 30 feet. The forest canopy is
moderately dense. Trees, limbs, and persistent herbaceous plants that remain visible throughout the year
dominate this area. The understory is thick on the western half with briars and more upland vegetation.
The understory on the eastern half is less dense and contains lower-lying vegetation, including some that
is more typical of wet environments. The bottomlands also consist of three primary drainage ditches:
one to the west, one in the center bisecting the forest, and one to the south. A portion of the bottomlands
is located within a 100-year floodplain zone, which is colored in blue in Figure 12.
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Figure 10: General Area Location Map
rrr
GRAPHIC SCALE - IN FEET
PRAWN:
GENERAL AREAS LOCATION MAP
LCP HOLTRACHEM SITE - Rl REPORT
RIEGELWOOD, NORTH CAROLINA
APPROVAL:
PATE: JANUARY 2013
Note: yellow is Upland Process Area, orange is Upland Non-Process Area, and green is Wooded
Bottomland Area.
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Figure 11: Wetland Delineation Map
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Figure 12:100-year Flood Zone
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September 2017
5.3 Surface and Subsurface Features
5.3.1 Upland Process Area
The UPA currently contains perimeter fencing, several structures and buildings, nine above ground
storage tanks (ASTs), several storm water collection basins connected to an underground piping system
to capture storm water, paved and gravel roads, concrete foundations of former operational structures, a
railroad spur, and a wastewater treatment system.
Access Structures
Fencing - An eight-foot high chain link fence that runs from the northwest property boundary to
the southeastern portion of the property controls access. Three access gates are part of the
fencing. No fencing is present along the site and Cape Fear River boundary or the eastern
wooded boundary between the site and IP.
Railroad Spur - A railroad spur on-site is the terminus of an active railroad track that leaves the
site in a southwestern direction.
Buildings
Five buildings remain at the site as described below and shown in Figure 13.
Office Building - The office building is currently used for administration, laboratory and worker
support activities. It is a single story, approximately 9,600 square foot brick and cinder block
structure.
Prep Building - The Prep Building is currently used for general material storage. It is a single
story, approximately 2,100 square foot metal structure.
Membrane Building - The Membrane Building is currently used for material storage (e.g. drums,
sandbags, various equipment). It is a single story, approximately 15,300 square foot metal
structure with a corrugated exterior.
Reagent Building - The Reagent Building is currently used to store chemicals, drums from
former assessment activities, and site equipment. It is a single story, approximately 2,400 square
foot metal structure.
Maintenance Building - The Maintenance Building is not in use. It is a single story,
approximately 6,000 square foot brick and metal structure.
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September 2017
Figure 13: Buildings Remaining On-site
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September 2017
Partially Dismantled UPA Components
Six process components were partially dismantled. Partially dismantled remaining structures are shown
in Figure 14 and include:
Cell Building Pad - The Cell Building Pad is an approximately 20,000 square foot (ft2) concrete
floor of the former Mercury Cell Building. Contractors dismantled and removed the mercury cell
building during the 2002-2004 Removal Action. Engineered Stockpile #1, which contains
approximately 6,700 yd3 of WWTS, is currently on top of the pad.
Cell Pit - The Cell Pit is immediately adjacent to the Cell Building Pad. It has an approximate
capacity of 60,000 gallons.
Retort Pad - The Retort Pad is an approximately 4,000 ft2 concrete structure of the former
mercury retort operation. A liner and clean backfill material currently cover it.
Former Bleach area - The former bleach area consists of remnant concrete structures of that
operation.
Former Brine Tank area - The former brine tank area (also referred to as the Brine Saturators in
the Old Salt Dock area) consists of remnant concrete pads.
UPA RCRA Units
Roberts Pond - Roberts Pond was a former solid waste management unit (SWMU). It was closed
under RCRA, but did not receive clean closure certification. About half of it is currently
underneath the Membrane Building, and the other half is beneath a dirt and gravel drive.
Solid Waste Disposal Site (SWDS) The SWDS, also referred to as the Vault, has an asphalt
cover. It is a RCRA unit that is currently beneath Engineered Stockpile #2.
Temporary Engineered Stockpiles (ESP)
WWTS from IP containing PCB-contaminated soils and sludge with concentrations greater than 50
mg/kg are enclosed in two engineered stockpiles. Both stockpiles consist of top and bottom high density
polyethylene (HDPE) liners that are sealed together to fully encapsulate the WWTS.
Stockpile #1 contains approximately 6,700 yd3 of WWTS and covers the entire footprint of the
Cell Building Pad.
Stockpile #2 contains approximately 15,800 yd3 of WWTS, concrete, and piping, and covers the
entire footprint of the SWDS. This stockpile has a leachate extraction system consisting of three
vertical de-watering pipes placed on the north end, the east side and the west side of the
stockpile. The system was installed to remove fluid buildup from water drainage of the WWTS.
Fluid buildup within this stockpile was pumped into 55-gallon drums.
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Figure 14: Partially Dismantled Process Area
SWDS
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Storm water/Waste water Treatment Components
Stormwater Collection System - The storm water collection system consists of a series of catch
basins and concrete underground piping that directs surface water run-off within the UPA to the
retention basins in the UNPA. The underground piping has deteriorated in many sections.
MESS Head Area - The MESS Head area consists of a sub-grade sump, a 20,000-gallon tank
and a filter press. Pre-treatment of mercury-contaminated wastewater, prior to discharge to final
treatment, occurred in the MESS Head Area.
Wastewater Treatment Plant - The wastewater treatment plant consists of a borohydride
treatment system, ASTs and a treatment pool (referred to as the Econo Pool). Wastewater is
treated and pumped to IP, where the treated effluent mixes with IP's wastewater for further
treatment and discharge.
IP Mill and Fire Protection Water - IP provides water to the site through underground piping. A
transite pipe runs underground from the southwest corner of the site towards the east to the
wastewater treatment plant. The underground piping for fire protection water is an 8-inch ductile
iron pipe that generally loops the central portion of the UPA. Several fire hydrants associated
with this system are present on site.
ASTs are used for wastewater processing and storage. The AST identifier, their capacities and
location are included in Table 3.
Table 3: Above Ground Storage Tanks
Identifier
Volume in
gallons
Location
Collection Tank#l
9,000
Wastewater T reatment Area
Collection Tank #2
18,000
Wastewater Treatment Area
Collection Tank #3
20,000
Wastewater Treatment Area
Mess Head Tank
20,000
MESS Area
North Storm water
22,000
Bleach Plant Area
South Storm water
22,000
Bleach Plant Area
North Raven
20,000
Wastewater Treatment Area
South Raven
20,000
Wastewater Treatment Area
Econo Pool
250,000
Wastewater Treatment Area
5.3.2 Upland Non-Process Area
The UNPA contains two surface impoundments and two retention basins surrounded by grassed areas.
The two surface impoundments, referred to as the Old North Pond and Old South Pond, are covered
with soil/gravel and low-lying grass, respectively. The retention basins capture storm water in addition
to wastewater. The south retention basin contains the initial effluent from the collection systems. Water
from this basin is transferred to the Econo Pool for treatment. The north retention basin collects
rainwater that falls into it, as well as serving as an overflow measure for the south retention basin.
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Figure 15: Upland Non-Process Areas (with some UPA features also shown)
Ofd Ndrth
^ond
North Retention
Basin
Old South
Pond
South Retention
Basin
Econo
Pool
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September 2017
5.3.3 Wooded Bottomland Area
The WBA does not contain any man-made surface or subsurface features.
Figure 16: Wooded Bottomland Area
5.4 Sampling Strategy
RCRA referred the site to Superfund in 2002. Since that time, several different entities have conducted
numerous sampling events. The sections below provide a summary of the field activities conducted
since 2002, and incorporation of historical RCRA data where appropriate.
5.4.1 Surveys
Surface features of the site were documented through historical engineering drawings, aerial and field
surveys by registered land surveyors (RLS), field measurements and observations. The information
below provides a general description of these surveys:
1978: Simons - Eastern Company, Inc. prepared a survey plat of the process area and related
topographic conditions, operational areas, and drainage features. Historical surface features were
also evaluated through vintage engineering drawings.
1999: American Geographic. Inc. RLS conducted a topographic aerial survey of the site and
portions of the surrounding IP property using the National Geodetic Vertical Datum of 1929
(NGVD 29). This survey was conducted as part of a RCRA Hazardous Waste Permit application
renewal. The geospatial data from this survey was later used in the initial portions of the EE/CA
Phase I investigation.
2005: W. K. Dickson RLS completed a survey of the former and newly installed groundwater
monitoring wells within the UNPA using the NGVD 29.
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2006: Taylor Wiseman & Taylor RLS conducted a survey of the site's topography, drainage
features and horizontal control for the site structures, the EE/CA Phase II soil, sediment, surface
water, and air sampling locations, and groundwater monitoring wells using the NAVD 88.
Sampling locations from previous assessment work including the iESI/RA and EE/CA Phase I
investigations were incorporated into the 2006 survey. This survey has been used as a base map
for subsequent sampling efforts.
2007: CH2M Hill conducted a survey of the drainage channels in the WBA using a Global
Positioning System (GPS) unit.
2009: Cape Fear Design Services prepared an as-built survey of the two engineered stockpiles.
5.4.2 Air
The following historical information was reviewed to evaluate meteorological data and characterize the
atmospheric transport of contaminants:
air quality records and related air permits for the discharge of chlorine, hydrochloric acid, and
mercury during facility operations;
past operational processes including the impregnation of Aroclor 1268 into graphite anodes and
mercury emissions from the cell building ventilation fans;
the Waccamaw Atmospheric Mercury Study published by the North Carolina Division of Air
Quality in March 2002, which examined air quality in the Riegelwood area from 1998 to 2000.
Monitoring
From 2002 to the present, air monitoring for mercury occurs daily when staff are present on-site. In
September 2005, a radiation survey was conducted.
Sampling
Between December 2004 and May 2007, seven Time Integrated Air Sampling (TIAS) events were
conducted. These events took place quarterly and consisted of six days of sample collection performed
within a three-week period. Air samples were collected using air sample pumps over a six to seven-hour
period each day from six locations surrounding the former Cell Building's concrete pad.
In 2005, air samples were collected to evaluate indoor air. The buildings sampled included the Office
Building, Membrane Building, Prep Building, and Air Compressor Building. Samples were collected
from both inside the buildings and just outside exits to the buildings.
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5.4.3 Surface Water and Sediment
5.4.3.1 Surface Water Sampling
During 2002, 2004, 2005, 2006 and 2009, a total of 40 surface water samples were collected at the site
and surrounding waterways. The sampling conducted in 2002 was part of the iESI/RA. The sampling
conducted in 2004 and 2005 was part of the EE/CA. The sampling in 2006 was immediately following a
storm event to evaluate potential surface water transport of contamination. The sampling conducted in
2009 was to fill in data gaps in order to complete the Baseline Ecological Risk Assessment (BERA). The
focus of each sampling event varied in purpose, location and analysis and is summarized in Table 4.
Table 4: Surface Water Sampling Strategy Summary 2002-2009
Area
# of
samples
Parameters
Sample
Year
Sample ID
Cape Fear River
3
Full Scan
2002
LCP-001, -006, -007
Cape Fear River
1
TAL Metals, TCL VOCs and SVOCs
2002
LCP-005
4
Number of Surface Water Samples Collected In 2002
Cape Fear River
6
Full Scan; Aroclor 1268; pH; Dioxins for IP-2
2004
IP-2; River Ref-1; River Up-1, -2;
River Down-1, -2
Livingston Creek
1
Full Scan; Aroclor 1268
2004
Wright-2
7
Number of Surface Water Samples Collected In 2004
Cape Fear River
3
Mercury
2005
SW-1, -2, -3
Western Drainage Ditch
3
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins for SW-11,-12
2005
SW-11, -12, -28
Eastern Drainage Ditch
7
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins forSW-22
2005
SW-17, -18, -20, -22, -24, -29, -30
Central Drainage Ditch
5
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins for SW-7, -13, -15
2005
SW-7, -9, -10, -13, -15
18
Number of Surface Water Samples Collected In 2005
Stormwater Event
2
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins
2006
SW-4, -14
Western Drainage Ditch
Stormwater Event
Central Drainage Ditch
2
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins; (SW-5 no TOC analysis)
2006
SW-5, -16
Stormwater Event
3
Full Scan; Aroclor 1268; TOC; Hardness; TSS;
Dioxins
2006
SW-6, -8, -19
Eastern Drainage Ditch
7
Number of Surface Water Samples Collected In 2006
Eastern Drainage Ditch
3
Full scan (no VOCs); Aroclor 1268; pH;
Hardness; methyl mercury; amphibian toxicity
2009
SW-40, -41, -42
Background Off-site
1
Full scan; Aroclor 1268; methyl mercury
2009
SWREF-1
4
Number of Surface Water Samples Collected In 2009
40
TOTAL NUMBER OF SURFACE WATER SAMPLES 2002-2009
Notes:
Full Scan = Target Analyte List Metals (TAL metals); Target Compound List Volatile Organic Compounds (TCL VOCs), Semi-Volatile Organic
Compounds (SVOCs), Polychlorinated Biphenyls (PCBs) + Aroclor 1268, pesticides (Aroclor 1268 is noted when added to the PCB analysis).
TOC = Total Organic Carbon
TSS =Total Suspended Solids
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5.4.3.2 Sediment Sampling
Over 130 sediment samples were collected in the combined years of 2002, 2004, 2005, 2007 and 2009.3
The sampling conducted in 2002 was part of the iESI/RA. The sampling conducted in 2004 and 2005
was part of the EE/CA. The sampling conducted in 2007 was to address data gaps identified at the
conclusion of the EE/CA Phase 2 sampling. The sampling conducted in 2009 was to fill in data gaps in
order to complete the BERA. The focus of each sampling event varied in purpose, location and analysis
and is summarized in Table 5.
Table 5: Sediment Sampling Strategy Summary 2002-2009
Area
# of
samples
Parameters
Year
Sample ID
Central Drainage Ditch
2
Full Scan; Total Cyanide
2002
HC-15, -16
Eastern Drainage Ditch
7
Full Scan; Total Cyanide
2002
HC-17 through HC-22
Cape Fear River
4
Full Scan; Dioxins
2002
LCP-001, -002, -005 and -007
13
Number of Sediment Samples Collected
in 2002
Cape Fear River
9
Full Scan; Aroclor 1268; TOC;
pH; Dioxins for IP-1, -3
2004
IP-1, -3; Site-1, -2; River Up-1,
-2; River Down-1, -2; and
Creek Discharge
Sewer System (SS)
5
Full Scan; Aroclor 1268
2004
SED-1 through -4, -6
Cape Fear River
Background
5
Full Scan; Aroclor 1268; TOC
2004
River Ref-1 through Ref-5
North Retention Basin
3
Full Scan; Aroclor 1268; TCLP
2004
SED-7, -8
South Retention Basin
4
Full Scan; Aroclor 1268; TCLP
2004
SED-9, -10
Livingston Creek
3
Full Scan; Aroclor 1268; TOC
2004
Wright-1 through -3
Central Drainage Ditch
5
Full Scan; Aroclor 1268
2004
WSED-1 and -2
Eastern Drainage Ditch
6
Full Scan; Aroclor 1268
2004
WSED-3 through -5
40
Number of Sediment Samples Collected
in 2004
Eastern Drainage Ditch
8
Mercury, PCB; Aroclor 1268;
TOC; pH for WSED-19
2005
WSED-16, -19, -21, -25
Eastern Drainage Ditch
16
Full Scan; Aroclor 1268; TOC;
pH; Dioxins for WSED-17, -18,
-20
2005
WSED-17, -18, -20, -22 to -
24, -29, -30
Western Drainage Ditch
6
Full Scan; Aroclor 1268; TOC;
Dioxins for WSED-28
2005
WSED-26 to -28
Central Drainage Ditch
10
mercury; PCB; Aroclor 1268;
TOC
2005
WSED-6, -8, -11, -12, -14
Central Drainage Ditch
10
Full Scan; Aroclor 1268; TOC;
pH; Dioxins for WSED-9
2005
WSED-7, -9, -10, -13, -15
50
Number of Surface Water Samples Collected in 2005
Western Drainage Ditch
3
Aroclor 1268
2007
WSED-39
Eastern Drainage Ditch
4
Mercury
2007
WSED-31, -32
Central Drainage Ditch
9
Aroclor 1268
2007
WSED-33, -35, -37
Central Drainage Ditch
4
Mercury
2007
WSED-34, -38
3 Note: This does not include the sampling conducted by IP's contractors in their former wastewater treatment lagoon.
Information about sampling of that area is included in section 5.4.4.3.
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September 2017
# of
Area
samples
Parameters
Year
Sample ID
Central Drainage Ditch
3
mercury and Aroclor 1268
2007
WSED-36
23
Number of Sediment Samples Collectec
in 2007
Eastern Drainage Ditch
4
Full scan (no VOCs); Aroclor
1268; methyl mercury
2009
WSED-40, -41, -42, SEDREF-1
Background Off-site
1
Full scan; Aroclor 1268;
methyl mercury
2009
SEDREF-1
5
Number of Sediment Samples Collected
in 2009
131
TOTAL NUMBER OF SEDIMENT SAMPLES 2002-2009
Notes:
Full Scan = Target Analyte List Metals (TAL metals); Target Compound List Volatile Organic Compounds (TCL VOCs), Semi-Volatile
Organic Compounds (SVOCs), Polychlorinated Biphenyls (PCBs) + Aroclor 1268, pesticides (Aroclor 1268 is noted when added to the
PCB analysis).
TCLP = Toxicity characteristic leaching procedure
TOC = Total Organic Carbon
5.4.3.3 WWTS
During June through October 2008, 19 samples were collected of the WWTS transported to the ESPs.
Samples were collected at a rate of one sample per approximately 1,000 yd3. The purpose was to assist
in evaluating treatment options for this material relative to constituents other than PCBs.
5.4.4 Geology
Geological investigations for the site and surrounding area included research of published literature of
the regional and local geologic conditions, and the evaluation of subsurface information obtained during
geological and environmental investigations.
Over 50 soil borings were advanced at the site primarily for purposes of geologic evaluation and well
installation. The majority of the borings were drilled in the mid-1980s through the late 1990s. This work
focused primarily on the surficial portion (upper 30 to 40 feet) of the underlying materials within the
UNPA near the two closed surface impounds (Old North and South Ponds), the retention basins, and the
WBA. Deeper subsurface conditions were also investigated while the site was regulated under RCRA by
drilling and sampling three soil borings to depths of approximately 140 ft bgs and one boring to
approximately 200 ft bgs. Down-hole geophysical logging, including electrical (apparent resistivity,
spontaneous potential) and gamma logging, was performed on each of the four deep borings. Grain size
distribution analyses was also conducted. In 2004, seven additional groundwater monitoring wells were
installed in the UP A, with depth ranges of 12 to 20 ft bgs.
5.4.5 Soil
Over 660 soil samples were collected in the years 2002 - 2005, 2007 and 2009. In 2002, soil samples
were collected during the iESI/RA. In 2003, high-density soil sampling was performed around the Retort
Pad perimeter; surface and subsurface soil samples were collected from 46 locations. In 2004, two soil
sampling events occurred. The first one was part of legal discovery in which surface and subsurface soil
samples were split from the plaintiffs' consultant. The second soil sampling event in 2004 was
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conducted as part of the EE/CA Phase 1 activities. In 2005, soil samples were collected as part of
EE/CA Phase 2 activities. At the completion of the Phase 1 work, mercury and Aroclor 1268 were
identified as the primary contaminants the site. Vertical and horizontal delineation sampling was
performed in areas identified in Phase 1 with high concentrations of mercury and/or Aroclor 1268. In
2007, surface and subsurface soil samples were collected from 21 locations in the WBA to address data
gaps identified after the EE/CA Phase 2 sampling was completed. In 2009, CH2M Hill collected 16
additional soil samples from the WBA to fill in data gaps in order to complete the BERA. The focus of
each sampling event varied in purpose, location and analysis and is summarized in Table 6.
Table 6: Soil Sampling Strategy Summary 2002-2009
Area
# of
samples
Parameters
Sample
Year
Sample ID
Background Off-site
3
Full Scan
2002
HC-23
Fill Area
7
Full Scan; Total Cyanide
2002
HC-06, -07, -12
Old Parking Area
2
Full Scan; Total Cyanide
2002
HC-24
Retort Area
15
Full Scan; Total Cyanide
2002
HC-01 to -05
Roberts Pond
6
Full Scan; Total Cyanide
2002
HC-08 and -09
WBA
2
Full Scan; Total Cyanide
2002
HC-13 and -14
35 Soil Samples Collected in 2002
Retort Area
118
mercury
2003
LC Samples
118 Soil Samples Collected in 2003
Litigation Samples
22
mercury, PCB; Aroclor 1268
2004
Site #1 Bl, #1 B2, #1 B3,
#1 B4, #1 Surface, #2 Bl,
#2 B2, #2 Debris, #2
Surface
Background
6
Full Scan; Aroclor 1268
2004
SB-26 to -28
Bleach Plant
1
Full Scan; Aroclor 1268
2004
SB-15
North Cell Building Pad Area
5
Full Scan; Aroclor 1268
2004
SB-4, -11, -12
Old Parking Area
6
Full Scan; Aroclor 1268; pH
2004
SB-21 to -23
Old Salt Dock
2
Full Scan; Aroclor 1268
2004
SB-13
Products Area
2
Full Scan; Aroclor 1268
2004
SB-14
Rail Yard Area
5
Full Scan; Aroclor 1268
2004
SB-5, -16, -17
Rail Yard Area
7
mercury and Aroclor 1268
2004
Site #3 Bl, Site #3
Surface
Retort Area
4
Full Scan; Aroclor 1268
2004
SB-1, -2
SWDS
6
Full Scan; Aroclor 1268; SPLP
2004
W-l, W-2 and W-3
South Cell Building Pad Area
2
Full Scan; Aroclor 1268; pH
2004
SB-9
Wastewater Treatment Area
3
Full Scan; Aroclor 1268; pH
2004
SB-19 and -20
West Cell Building Pad Area
10
Full Scan; Aroclor 1268
2004
SB-3, -6, -7, -8, -10
81 Soil Samples Collected in 2004
Background
6
Full scan; Aroclor 1268;
Dioxins; TOC
2005
SB-104 to -106
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Summary of Remedial Alternative Selection
September 2017
Area
# of
samples
Parameters
Sample
Year
Sample ID
East Cell Building Pad Area
2
Full scan; Aroclor 1268;
Dioxins
2005
SB-73
East Cell Building Pad Area
18
mercury
2005
SB-118 to -121, -134, -
135
Fill Area
69
Aroclor 1268
2005
SB-47 to -56, -58, -59, -
301, -302
North Cell Building Pad Area
16
Aroclor 1268
2005
SB-30, -31, -33 to -38
North Cell Building Pad Area
15
mercury
2005
SB-122 to -126
Old North Pond
3
Full scan; Aroclor 1268;
Dioxins for SB-77
2005
SB-76 to -78
Old North Pond
1
Full scan (no VOCs); Aroclor
1268
2005
UNP-5
Old Parking Area
6
Aroclor 1268
2005
SB-65 to -67
Rail Yard Area
22
Aroclor 1268
2005
SB-39 to -42, -57, -64
Rail Yard Area
4
Full scan; Aroclor 1268;
Dioxins
2005
SB-71, -74
Retort Area
25
Aroclor 1268
2005
SB-43 to -46, -60
Retort Area
8
Full scan; Aroclor 1268;
Dioxins
2005
SB-68 to -70
Retort Area
65
mercury
2005
SB-108 to -117, -136 to -
150,-152 to -154
Roberts Pond
15
Aroclor 1268
2005
SB-61 to -63
SWDS
6
Total metals
2005
W-4 to -6
South Cell Building Pad Area
2
Full scan; Aroclor 1268;
Dioxins
2005
SB-72
South Cell Building Pad Area
6
mercury
2005
SB-132, -133
Wastewater T reatment Area
2
Full scan; Aroclor 1268;
Dioxins
2005
SB-75
West Cell Building Pad Area
2
Aroclor 1268
2005
SB-29, -32
West Cell Building Pad Area
21
mercury
2005
SB-127 to -131, -155 to -
157
North Retention Basin
5
Full scan; Aroclor 1268;
Dioxins for SB-102, -103, 310
2005
SB-81, -82, -102, -103, -
310
South Retention Basin
2
Full Scan; Aroclor 1268
2005
SB-83, -84
WBA
2
Full Scan; Aroclor 1268
2005
SB-79 and -80
WBA
22
Full scan; Aroclor 1268;
Dioxins; TOC for SB-98; VOCs
and SVOCs for SB-89
2005
SB-85 to -101
345 Soil Samples Collected in 2005
WBA 59 Aroclor 1268 2007 SB-158 to -178
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September 2017
Area
# of
samples
Parameters
Sample
Year
Sample ID
59
Soil Samples Collected in 2007
WBA
17
Full scan; Aroclor 1268
2009
TERA-1 to -5, WB-1 to -5
UNPA
5
Full scan; Aroclor 1268
2009
UNP-1 to -5
Background Off-site
1
Full scan; Aroclor 1268;
methyl mercury
2009
SEDREF-1
23
Soil Samples Collected in 2009
TOTAL OF
661
SOIL SAMPLES 2002-2009
Notes:
Full Scan = Target Analyte List Metals (TAL metals); Target Compound List Volatile Organic Compounds (TCL VOCs), Semi-Volatile
Organic Compounds (SVOCs), Polychlorinated Biphenyls (PCBs) + Arodor 1268, pesticides (Aroclor 1268 is noted when added to the
PCB analysis).
SPLP = synthetic precipitation leaching procedure
TOC = Total Organic Carbon
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September 2017
5.4.6 Groundwater
Prior to the year 2000, over 50 groundwater monitoring wells were installed at the site. In 2004, seven
groundwater monitoring wells were installed in the UPA as part of the EE/CA. In 2012, one additional
groundwater monitoring well was installed in the WBA near the head of the central drainage ditch.
Some of the wells have been abandoned or destroyed. Currently there are 45 groundwater monitoring
wells on-site. All of the wells consist of PVC pipes with diameters ranging from one to four inches. A
summary of the construction data for the wells currently on-site is in Table 7.
Table 7: Groundwater Monitoring Well Construction Information
Well ID
Date
Installed
Screen
Interval
(ft bgs)
Well
Diameter/
Type
Current Status
BG
4/20/1992
18-28
2"/P VC
Background Monitoring Well
NUS-4R
4/20/1992
12.5-17.5
4"/PVC
Monitor
ng Well
4A
11/24/1986
10-15
2"/PVC
Monitor
ng Well
4B
11/24/1986
25-30
2 "/PVC
Monitor
ng Well/Piezometer
5A
11/24/1986
15-20
2"/PVC
Monitor
ng Well
5B
11/24/1986
30-35
2"/PVC
Monitor
ng Well/Piezometer
6A
11/24/1986
15-20
2"/PVC
Monitor
ng Well/Piezometer
6B
11/24/1986
30-35
2"/PVC
Monitor
ng Well/Piezometer
B8
10/20/1986
13-23
2"/PVC
Monitor
ng Well/Piezometer
9A
Jun-1989
~l-6
2"/PVC
Monitor
ng Well
9B
Jun-1989
~5-10
2 "/PVC
Monitor
ng Well/Piezometer
9C
Jun-1989
-8.5-13.5
2"/PVC
Monitor
ng Well/Piezometer
10AR
1/13/2000
10-20
2"/PVC
Monitor
ng Well
10BR
6/23/1999
34.5-39.5
2"/PVC
Monitor
ng Well
11A
1/19/1987
14-19
2"/PVC
Monitor
ng Well
11B
1/19/1987
29-34
2"/PVC
Monitor
ng Well
11C
2/16/1990
14-23.5
2"/PVC
Monitor
ng Well/Piezometer
12A
1/19/1987
10-15
2"/PVC
Monitor
ng Well/Piezometer
12B
1/20/1987
29.5-34.5
2"/PVC
Monitor
ng Well/Piezometer
13A
1/20/1987
10-15
2"/PVC
Monitor
ng Well
13B
1/20/1987
29.5-34.5
2"/PVC
Monitor
ng Well/Piezometer
14A
1/20/1987
10-15
2"/PVC
Monitor
ng Well
14B
1/20/1987
24.5-29.5
2 "/PVC
Monitor
ng Well/Piezometer
POC-1R
Dec-1999
14-19
4"/PVC
Monitor
ng Well
POC-2R
1/12/2000
10-20
4"/PVC
Monitor
ng Well
POC-3
4/20/1992
13.5-18.5
4"/PVC
Monitor
ng Well
PZ-1
11/20/2001
2-12
2"/PVC
Monitor
ng Well/Piezometer
PZ-2
11/20/2001
1.5-11.5
2 "/PVC
Monitor
ng Well/Piezometer
PZ-3
11/20/2001
1.5-11.5
2"/PVC
Monitor
ng Well/Piezometer
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Summary of Remedial Alternative Selection
September 2017
Well ID
Date
Installed
Screen
Interval
(ft bgs)
Well
Diameter/
Type
Current Status
PZ-4
11/20/2001
2-12
2 "/PVC
Monitoring Well/Piezometer
PZ-5
11/20/2001
2-12
2"/PVC
Monitoring Well/Piezometer
PZ-6
11/20/2001
2-12
2"/PVC
Monitoring Well/Piezometer
P5
8/11/1999
10-20
r/pvc
Monitoring Well/Piezometer
P6
8/11/1999
10-20
rypvc
Monitoring Well/Piezometer
P8
8/11/1999
10-20
i"/pvc
Monitoring Well/Piezometer
P9
8/2/2012
2-7
2"/PVC
Monitoring Well/Piezometer
RW-1
2/14/1990
14.2-23.7
4"/PVC
Recovery well/Inactive
RW-2
2/15/1990
17.4-26.9
4"/PVC
Recovery well/Inactive
MW-15
11/4/2004
2-12
4"/PVC
Monitoring Well
MW-16
11/10/2004
4.2-14.2
4"/PVC
Monitoring Well
MW-17
11/11/2004
3.4-13.4
4"/PVC
Monitoring Well
MW-18
11/9/2004
4.8-14.8
4"/PVC
Monitoring Well
MW-19
11/9/2004
7.7-17.7
4"/PVC
Monitoring Well
MW-20
11/9/2004
8.7-18.7
4"/PVC
Monitoring Well
MW-21
11/11/2004
9.3-19.3
4M/PVC
Monitoring Well
Notes:
ft bgs = feet below ground surface
PVC = polyvinyl chloride
5.4.6.1 Groundwater Level Measurements
Groundwater levels have been measured for differing purposes over time. In the mid-1980s water levels
were measured to evaluate the vertical and horizontal gradients of the underlying aquifers. Since 2004,
three groundwater gauging events (2004, 2007 and 2009) were conducted to evaluate groundwater flow
conditions as part of the EE/CA and RI work.
5.4.6.2 Aquifer Testing
Slug testing was performed on over 20 wells to assess subsurface hydraulic conductivity. In addition to
the slug testing, long term groundwater extraction rates from recovery wells RW-1 and RW-2 were
evaluated for purposes of RCRA corrective action. The hydraulic conductivity values and flow rates
from the recovery wells were used in developing the hydrogeologic characteristics at the site.
5.4.6.3 Groundwater Sampling and Analysis
Historical RCRA compliance monitoring activities included: quarterly monitoring for mercury and
indicator parameters for 12 compliance monitoring wells and one background monitoring well (1992
through 2003); and annual monitoring for RCRA Appendix 9 constituents from the point of compliance
(POC) monitoring wells during January 1993 through December 2003.
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Under CERCLA, groundwater samples were collected and analyzed in 2002, 2004, 2008,2009, and
2012. The sampling conducted in 2002 was performed during the iESI/RA. The sampling conducted in
2004 and 2009 were part of the EE/CA and RI. The single sample collected in 2008 was during the IP
Removal Action. The single sample collected in 2012 was to fill in a data gap for completion of the RI.
The focus of each sampling event varied in purpose, location and analysis and is summarized in Table 8.
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September 2017
Table 8: Groundwater Sampling Strategy Summary
Area
#of
samples
Parameters
Sample Year
Sample ID
UPA
1
Hg, inorganics
1992-2003 (Q)
BG
UNPA
7
Hg, inorganics
1992-2003 (Q)
POC-2R, 10AR, 10 BR, 11A, 11B, 13A,
14A
WBA
5
Hg, inorganics
1992-2003 (Q)
POC-3, NUS-4R, 4A, 5A, 9A
13 Groundwater Samples Collected Each Quarter during 1992-2003
UNPA
2
Appendix 9
1993-2003 (A)
POC-1R*, POC-2R
WBA
1
Appendix 9
1993-2003 (A)
POC-3
3 Groundwater Samples Collected Annually during 1993-2003
Old Parking Area
1
Full scan
2002
HC-24
Roberts Pond
1
Full scan
2002
HC-09
Fill Area
1
Full scan
2002
HC-07
Retort Area
5
Full scan
2002
HC-01 to -05
8 Groundwater Samples Collected in 2002
UPA
8
Full scan; Aroclor 1268;
cations & anions
2004
BG; MW-15, -16, -17, -18, -19, -20, -
21
UNPA
2
Full scan; Aroclor 1268;
cations & anions
2004
POC-2R, 14A
WBA
4
Full scan; Aroclor 1268;
cations & anions
2004
POC-3R, NUS-4R, 6A, 6B
14 Groundwater Samples Collected in 2004
SWDS
1
Hg; Aroclor 1268
2008
AV-1
1
Groundwater Samples Collected in 2008
UPA
8
Full scan; Aroclor 1268;
cations & anions
2009
BG; MW-15, -16, -17, -18, -19, -20, -
21
UNPA
3
Full scan; Aroclor 1268;
cations & anions
2009
POC-2R, 11 A, 14A
WBA
3
Full scan; Aroclor 1268;
cations & anions
2009
POC-3R, NUS-4R, B8
14 Groundwater Samples Collected in 2009
WBA
1
Hg; Aroclor 1268
2012
P9
1 Groundwater Sample Collected in 2012
Notes:
Full Scan = Target Analyte List Metals (TAL metals); Target Compound List Volatile Organic Compounds (TCL VOCs), Semi-Volatile
Organic Compounds (SVOCs), Polychlorinated Biphenyls (PCBs) + Aroclor 1268, pesticides (Aroclor 1268 is noted when added to the
PCB analysis).
A = annually
Hg = mercury
Q= quarterly
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September 2017
5.5 Sources of Contamination
5.5.1 On-site
Based on the site use and operational history, the manufacturing process areas represent the bulk of the
potential source areas. Mercury and Aroclor 1268 are the contaminants that pose the greatest risks to
human health and the environment (see Section 7.0, Summary of Site Risks). The facility operated a
mercury cell electrolytic process. The facility treated the graphite anodes of the mercury cell with
chlorinated hydrocarbons, including Aroclor 1268, to remove impurities from the anodes. Mercury and
Aroclor 1268 are concentrated in operational areas and in the drainage pathways across the site. Other
contaminants posing risks were commonly located with these main contaminants.
Historical photographs and engineering drawings indicate that early plant operations may not have
adequately contained runoff from process areas. Storm water runoff from the chemical storage and
process operations was likely a primary source of contamination for the soils and sediment in the WBA.
Above ground sources of contamination was removed from the site as part of the 2002-2004 Removal
Action. These areas included the former Mercury Cell Building, the Retort equipment, the MESS
equipment, equipment and tanks within the Products Area, the salt brine saturator tanks and associated
equipment within Salt Dock Area, and equipment and tanks within the Bleach Plant area.
A summary of the remaining source areas:
The Cell Building Pad Area: This area is suspected to contain PTW. Elemental mercury was
observed in cracks and fissures in the concrete pad, prior to and following the removal of the
building. Mercury is likely present within the concrete pad and beneath the pad within the
underlying soils. However, the PRP's contractor did not conduct sampling to define the depth of
this contamination.
The Retort Pad Area: This area is suspected to contain PTW. Elemental mercury was observed in
cracks and fissures in the concrete pad, prior to and following the removal of the retort
equipment. Mercury is likely present within the concrete pad and immediately beneath the pad
within the underlying soils. Densely gridded soil sampling and analysis in this area indicated the
presence of mercury within the soils immediately adjacent to the concrete pad.
The Fill Area: The facility created the Fill Area in the late 1990s during the construction of the
Membrane Building. This area contains process chemicals and waste materials from past
operations.
PCB Impregnation and Use of Graphite Anodes: There is no available documentation regarding
using PCBs at the site. However, Aroclor 1268 was detected in site samples and in IP's waste
water treatment lagoon at concentrations that pose risks to human health and the environment.
Information regarding other chlor-alkali facilities suggest that Aroclor 1268 was likely used to
remove impurities from the graphite anodes.
The Solid Waste Disposal Site Area: This RCRA unit reportedly contains encapsulated process
sludge materials. Records indicate that the SWDS had a PVC liner and an asphalt cap. The waste
material was stabilized and the unit was closed in place.
The Old South Pond: This RCRA unit reportedly contains encapsulated process sludge materials
along with materials excavated from the Old North Pond. The Old South Pond has a synthetic
liner and cap
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The Old North Pond: This RCRA unit formerly contained wastes which were excavated,
stabilized, and placed into the Old South Pond. Afterwards it was backfilled with clean soil.
However, it did not receive RCRA clean closure status.
Robert's Pond Area: This RCRA unit operated for nearly a decade and was unlined. It was used
to dispose of brine wastes containing mercury impurities. Roberts Pond was excavated and
backfilled in 1987. The closure activities conducted at Robert's Pond did not satisfy requirements
for clean closure under RCRA authority. Historical soil sample analytical results from this area
suggest mercury is present in low concentrations within the soil.
The North and South Retention Basins: The North and South Retention Basins were constructed
sometime between the late 1970's to earlier 1980's. The basins receive surface water runoff,
which the facility pumps to the wastewater treatment area and processes it prior to discharge.
The retention basins are unlined but reportedly have a clay base or rest directly on top of the
Peedee Formation.
Sewer System: The sewer system winds through the UPA to carry process wastewater and storm
water to the Wastewater Treatment Area. The sewer system was evaluated via visual assessment
and video survey in 2002. The video survey was limited in some portions due to pipe blockages.
The video documented cracks near several of the joints and completely corroded piping in some
areas. It also documented multiple impacted areas north of the Cell Building Pad and in the
piping leading to and from the diversion chamber in the wastewater treatment area.
Historical Process Area Drainage Pathways: Historically, two other drainage pathways existed at
the site that no longer exist. One includes a former drain from IP through the northern portion of
the Manufacturing Process Area to the WBA. The second includes a former drainage ditch from
the Wastewater Treatment Area to IP's wastewater lagoon.
Wastewater Area: The sewer lines congregate in the Wastewater Area for processing. Processing
includes a settling tank, stabilization, flocculation, and filtration. Prior to development of the
Wastewater Area in 1987, the facility diverted process water and storm water through a drainage
ditch extending to the east from the wastewater treatment area to the adjacent IP facility for off-
site treatment and disposal. Herman's Hollow is a sump area that historically received pretreated
water from the Mercury Cell Building and associated process areas as well. The base of the sump
has eroded away and filled with sediment.
Wooded Bottomland Area: The WBA has been undeveloped throughout the site operational
history. The drainage areas in the WBA received unprocessed water prior to implementation of
environmental regulations.
Engineered Stockpiles: Although currently completely contained, PCB-contaminated material in
the engineered stockpiles described in Section 2.4.2, could become a source of contamination if
a remedial action does not occur.
5.5.2 Off-site
Potential off-site sources of contamination to the site may include current and former operations from
the adjacent IP facility. Historical information indicates two former sources of potential contamination
to the site.
Historical photographs and drawings indicate IP maintained an open ditch that discharged effluent
directly into the WBA. The source of this effluent was reportedly seepage from the black liquor pond
located to the west and adjacent to the site. This ditch was later covered and piped. IP closed the black
liquor pond in the mid-2000s. Black liquor is the spent cooking liquor from the kraft process when
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September 2017
digesting pulpwood into paper pulp removing lignin, hemicelluloses and other extractives from the
wood to free the cellulose fibers. Spent pulping liquor is a corrosive complex mixture with a pH ranging
from approximately 11.5 to 13.5. The inorganic constituents in black liquor come from the cooking
liquor used to pulp the wood chips and comprised of sodium hydroxide, sodium sulfide, sodium
carbonate, sodium sulfate, sodium thiosulfate and sodium chloride. Collectively, inorganic salts
constitute 18% to 25% of the solids in black liquor.
The process of bleaching pulp at paper mills using cellulose fibers produces dioxins and fiirans.
Currently, bleaching pulp and paper mills are the only significant known source of dioxins released into
surface waters. Since the IP mill used the chlorine gas produced from the site in their pulp bleaching
process, this facility may have contributed to the detectable concentrations of dioxins fiirans at the site
through air emissions and effluent discharges. IP reportedly began production of their own chlorine
dioxide in the 1990s. Published literature suggests that the use of chlorine dioxide in the bleaching
process at pulp and paper mills greatly reduces the production of dioxins and fiirans.
5.6 Types of Contamination and Affected Media
This section is organized by media. Contamination was found in all media (air, surface water, sediment,
WWTS, soil and groundwater) at varying concentrations. However, only soil, sediment and surface
water have concentrations detected of contaminants that pose risks to human health and the
environment. See Section 7.0 for information regarding risk assessments. Summaries of the sampling
results for each media are discussed in the following subsections.
5.6.1 Air
Air monitoring using a handheld mercury vapor analyzer began during the first removal action and
continues to occur daily when staff are present on-site. Documentation of air monitoring data is
extensive and is available in the site file.
Air samples were collected inside and outside of buildings on several occasions. The first event occurred
as part of the Post-Removal Site Control Plan (PRSCP) to evaluate whether mercury contributed to air
contamination from the former Mercury Cell Building pad after the first removal action was completed
(discussed further in Section 5.6.1.1), The second event occurred during the EE/CA-RI for the purposes
of determining if a risk was posed to human health via vapor intrusion (discussed further in Section
5.6.1.2).
5.6.1.1 Time Integrated Air Sampling
After the first removal action concluded at the site, (summarized in Section 2.4.2), seven Time
Integrated Air Sampling (TIAS) events occurred between December 2004 and May 2007. During each
sampling event, air samples were collected from six locations on six days during an approximate three-
week period. This resulted in the collection of over 250 air samples between 2004 and 2007.
The daily sampling period was approximately 6-7 hours. Sample locations included upgradient, center
of the mercury cell building pad, downgradient edge of the mercury cell building pad, and three other
downgradient locations. The locations for all but the center sample varied daily depending on the wind
direction.
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September 2017
On most dates, the laboratory detected mercury in the "blank" sample. The sample location with the
highest average mercury concentration overall was TI-D1. Table 9 includes sample results for that
location, minus the concentration found in the blank sample(s) of that batch.
Each sample location, except for the upgradient locations, had a mercury concentration that exceeded
the residential Removal Action Level (RAL) of 0.9 micrograms per cubic meter (|ig/m3) for mercury on
at least one day. Mercury concentrations ranged from not detected to 17 (ig/m3. All results were below
the commercial/industrial RAL of 25 (ig/m3. The laboratory did not detect mercury in any of the samples
on two dates: May 12, 2006 and May 15, 2007. The highest concentration detected was on May 16,
2006. Location D3 concentration was 17 (ig/m3 with location D1 a close second at 16 (ig/m3. The
temperature that day was 64-75°F and wind was coming from the west at 3 mph. The sample locations
for the May 16, 2006 sampling event are included in Figure 17. A summary of the results from 2004-
2007 are included in Table 9.
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September 2017
Figure 17: TlAS sample locations on date of highest concentrations
PROPERTY BOUNDARY
SITE FEATURES
4- WINO DIRECTION
TIME-tNTEOKATED SAMPLE LOCATIONS
9 CENTS? OF PAD
# DOWNWIND EDGE OF PAD
t DOWNWIND OF PAD
UPWIND OF PAD
GRAPHIC SCALE - IN FEET
100
200
jfMACTEC
TIME-INTEGRATED SAMPLING DATA (06136)
MAV 16, 2006
LCP - HOLTRACHEM SITE
RfEGELWOOO, NORTH CAROLINA
DRAWN:
WBM
APPROVAL:
SCALE:
AS SHOWN F»G:
JOB:
6550-06-0314
DATE: loU
REFERENCE: HONEYWELL\DWGS\2006\MAY06\MERCSAMPLIN^
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September 2017
Table 9: TIAS Data Summary for the Location with the Highest Average Concentration
location: Downgradient Edge of Pad (Tl-Dl)
Average
Average
Ambient
Blank
Concentration
Sampling
Temperature
Corrected
for Sampling
Event
Date
(°F)
Wind
Concentration
Event
11/29/2004
57
from NE @ 7mph
0.61
12/2/2004
55
from NE @4 mph
0.36
December
12/3/2004
55
from N/NW @ 6 mph
0.33
0.47
2004
12/8/2004
67
from SW @ 4 mph
0.68
12/13/2004
49
from SW @ 7 mph
0.39
12/16/2004
37
from N @ 1 mph
<0.2
3/30/2005
74-80
from ENE @ 2-8 mph
0.5
4/4/2005
69-78
from W @ 2-12 mph
1.36
March 2005
4/5/2005
76-83
from NE @ 2-4 mph
0.53
0.70
4/6/2005
75-84
from SE @ 3-6 mph
0.96
4/11/2005
70-77
from SE @ 2-4 mph
0.45
4/12/2005
66-69
from ESE @ 1-4 mph
0.37
6/21/2005
85
2.66
6/22/2005
77
0.38
June 2005
6/24/2005
84
0.24
1.09
6/28/2005
87
0.66
7/1/2005
87
0.65
7/6/2005
88
1.96
11/16/2005
72-76
from SE/S @ 5-11 mph
0.24
11/17/2005
52-56
from NW @ 8 mph
0.29
November
11/18/2005
38-50
from NW/N @8 mph
0.13
0.22
2005
11/22/2005
52-56
from NW/W shifting
0.23
11/23/2016
38-48
from W @ 1-6 mph
0.28
11/30/2016
60-78
from NW @ 5-8 mph
0.16
5/1/2006
60-72
from N/NW @ 3-8 mph
0.68
5/3/2016
75-84
from W/NW @ 9-11 mph
0.85
May 2006
5/5/2006
68-80
from S/SE @ 2-7 mph
1.4
4.11
5/10/2006
64-80
from SW @ 0-6 mph
1.6
5/12/2006
70-82
from S @6-16 mph
<0.26
5/16/2006
64-75
from W @ 3 mph
16
8/1/2006
88-100
from W/SW @ 3 mph
0.38
8/2/2006
80-100
from S@ 4-7 mph
4.8
August
8/3/2006
82-102
from S @ 2-4 mph
9.4
2.92
2006
8/7/2006
78-98
rom SW-NW/N @0-7mpt
0.92
8/9/2006
84-92
from N/NE @ 0-4 mph
0.94
8/15/2006
84-90
from S/SW/SE @ 2-4 mph
1.1
5/14/2007
74-82
From N/NW-NE @ 2-4mph
<0.3
5/15/2007
84-86
from SE/E-S @ 3-7 mph
<0.3
May 2007
5/21/2007
82-86
from SW @ 0-2 mph
0.7
0.63
5/23/2007
84-86
from SW @ 0-2 mph
<0.3
5/25/2007
84-86
from N-NE @ calm
0.7
5/30/2007
89-90
from W-NE @ 5-6 mph
0.5
Average:
1.47
1.45
Notes:
Samples were collected over a 6-7 hour period each day
All concentration results are in micrograms per cubic meter (pg/m3)
means that information was not included in the report's summary table
Blank Corrected means that the concentration of mercury detected in the blank sample for that day was
subtracted from the concentration detected in thesample.
Removal Action Levels (RALs) for mercury are 0.9 pg/m3 for residential and 25 pg/m3 for
Yellow highlight indicates concentration detected exceeds the residential RAl of 0.9 pg/m3
48
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.1.2 Vapor Intrusion Assessment Sampling
In 2004, air samples were collected from nine locations within primary buildings and immediately
adjacent to those buildings as part of a vapor intrusion (VI) evaluation. Table 10 summarizes the
analytical results.
Table 10: Vapor Intrusion Air Sample Results Summary
Analyte
Units
FOD%
Minimum
Cone.
Maximum
Cone.
mercury
mg/m3
33
0.0006
0.00078
Volatile Organic Compounds detected in at least one sample:
1,1,2-trichlorotrifluoroethane
PPBV
22
0.1 J
0.1 J
1,2,4-trimethylbenzene
PPBV
44
0.13 J
0.85
1,3,5-trimethylbenzene
PPBV
11
0.23 J
0.23 J
benzene
PPBV
89
0.22 J
1.3
bromomethane
PPBV
11
0.27 J
0.27 J
chlorobenzene
PPBV
11
0.13 J
0.13 J
chloroform
PPBV
89
0.22 J
0.96
chloromethane
PPBV
100
0.93
1.5
cis-l,2-dichloroethene
PPBV
11
1.1
1.1
dichlorodifluoromethane
PPBV
100
0.5
0.64
ethylbenzene
PPBV
44
0.27
0.5
methylene chloride
PPBV
11
0.39 J
0.39 J
m&p-xylene
PPBV
67
0.13 J
1.4
o-xylene
PPBV
33
0.44
0.52
styrene
PPBV
44
0.13 J
0.66
tetrachloroethene
PPBV
11
1.2
1.2
toluene
PPBV
89
0.23 J
2.9
trichloroethene
PPBV
11
0.31
0.31
trichlorofluoromethane
PPBV
100
0.23 J
1.2
vinyl chloride
PPBV
11
0.27
0.27
Notes:
Cone. = concentration
FOD% = percentage frequency of detection. 9 samples were analyzed for each analyte. Therefore, FOD% of 33
means that 3 of the 9 samples analyzed had detections of the analyte.
J = estimated value
mg/m3 = milligrams per cubic meter
PPBV = parts per billion volume
49
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Summary of Remedial Alternative Selection
September 2017
5.6.2 Surface Water
Surface water samples were collected from multiple locations in the on-site WBA drainage pathways,
the Cape Fear River and Livingston Creek. During 2004 through 2009, surface water samples were
collected in the WBA during five separate sampling events. The 2006 sampling events were to evaluate
conditions in the WBA drainage pathways when a storm event occurred. All three drainage paths
(eastern, central and western) flow to the Cape Fear River. Flow through the western drainage ditch is
ephemeral and dependent on rainfall, while flow through the central and east drainage ditches is
perennial.
This section is divided into three subsections: on-site surface water, on-site storm water and off-site
surface water. The laboratory reported multiple constituents detected. The following discussion provides
a summary of the surface water and storm water analytical results for each of these areas. The notes
below are applicable to each subsection table.
Notes:
CaC03 = calcium carbonate ___
Cone. = concentration
FOD% = percentage frequency of detection. For example, if 20 samples were analyzed for the analyte and only one had a
detection FOD would be 1/20 = 5%.
ng/L = nanogram per liter
|ig/L = micrograms per liter
5.6.2.1 WBA Surface Water
Water Quality Parameters
Seventeen surface water samples were collected from the WBA drainage ditches and analyzed for
hardness, Total Suspended Solids (TSS) and Total Organic Carbon (TOC). Table 11 summarizes the
frequency of detection, range of concentrations, and location of the maximum detected concentration.
Table 11: Bottomland Drainage Ditch Surface Water Data Summary - Water Quality Parameters
Minimum
Maximum
Max
Analyte
fOD%
Cone.
Cone.
location
Method E130.2. Concentration units are in |ig/L
hardness, Total as CaC03
100%
254,000
512,000
SW-9
Method E160.2. Concentration units are in |ig/L
Total Suspended Solids
100%
6,800
1,010,000
SW-24
Method SW9060. Concentration units are in |ig/L
total organic carbon (TOC)
100%
9,700
43,000
SW-10
50
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
VOCs
Seventeen surface water samples were collected from the WBA drainage ditches and analyzed for
VOCs. Collectively, the samples contained nine detected VOCs. Table 12 summarizes detected VOCs,
frequency of detection, range of concentrations, and the location of the maximum concentration.
Table 12: Bottomland Drainage Ditch Surface Water Data Summary- VOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
VOCs via method SW8260. Concentration units are in |j
1,2,4-Trichlorobenzene
g/L
6%
0.79
0.79
SW-24
1,3-Dichlorobenzene
18%
0.69
3.3
SW-29
1,4-Dichlorobenzene
12%
1.3
2.6
SW-29
acetone
6%
2
2
SW-28
carbon disulfide
6%
0.57
0.57
SW-2
chlorobenzene
12%
0.77
1.6
SW-29
chloromethane
6%
0.24
0.24
SW-28
tetrachloroethene (PCE)
6%
0.14
0.14
SW-28
trichloroethene (TCE)
6%
0.51
0.51
SW-29
SVOCs
Twenty surface water samples were collected from the WBA drainage ditches and analyzed for SVOCs.
Collectively, the samples contained seven detected SVOCs. Table 13 summarizes detected SVOCs,
frequency of detection, range of concentrations, and the location of the maximum concentration.
Table 13: Bottomland Drainage Ditch Surface Water Data Summary - SVOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
SVOCs via method SW8270. Concentration
1,1-biphenyl
units are in
33%
Mfi/L
0.023
0.023
SW-41
acenaphthene
10%
0.054
0.059
SW-40
anthracene
15%
0.023
0.048
SW-42
bis(2-Ethylhexyl)phthalate
20%
1.4
2.7
SW-11
carbazole
10%
0.031
0.031
SW-40, SW-41
fluoranthene
10%
0.074
0.13
SW-40
pyrene
15%
0.022
0.073
SW-40
51
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Twenty surface water samples were collected from the WBA drainage ditches and analyzed for
inorganics. Many inorganics are naturally occurring. Table 14 summarizes detected inorganics,
frequency of detection, range of concentrations, and the location of the maximum concentration.
Table 14: Bottomland Drainage Ditch Surface Water Data Summary - Inorganics
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Inorganics via method SW6010. Concentration units ar
aluminum
e in Mg/l
90%
119
8990
SW-2
arsenic
10%
5.8
6.8
SW-2
barium
100%
40.6
227
SW-2
cadmium
10%
5.8
6.8
SW-2
calcium
100%
54,200
172,000
SW-28
chromium
40%
0.82
20
SW-18
cobalt
10%
0.5
2.8
SW-2
copper
15%
3.2
8.4
SW-2
iron
95%
639
24,900
SW-2
lead
5%
11.3
11.3
SW-2
magnesium
100%
5,650
21,700
SW-42
manganese
100%
37.3
802
SW-30
nickel
70%
2
16.6
SW-2
potassium
100%
5,580
44,400
SW-9
selenium
20%
4.8
7.4
SW-7
sodium
100%
243,000
6,150,000
SW-9
vanadium
70%
3.2
41
SW-2
zinc
75%
6.9
181
SW-2
Mercury via methods SW7470 and SW7473. Concentration units are in ng/L
mercury 78% 0.07 22.9 SW-28
52
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Twenty surface water samples were collected from the WBA drainage ditches and analyzed for
pesticides. Collectively, the analysis detected eight pesticides. Table 15 summarizes detected pesticides,
frequency of detection, range of concentrations, and the location of the maximum concentration.
Table 15: Bottomland Drainage Ditch Surface Water Data Summary - Pesticides
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Pesticides via method SW8081. Concentration units ari
4,4'-DDD
i in iig/L
10%
0.023
0.024
SW-2
4,4'-DDT
10%
0.034
0.084
SW-7
delta-BHC
5%
0.045
0.045
SW 24
endosulfan II
5%
0.017
0.017
SW-7
endosulfan sulfate
5%
0.026
0.026
SW-28
endrin
5%
0.049
0.049
SW-24
endrin aldehyde
40%
0.022
0.26
SW-2
endrin ketone
33%
0.049
0.049
SW-40
53
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
PCBs
Twenty surface water samples from the WBA drainage ditches and were analyzed for Aroclors and four
samples were analyzed for PCB congeners. Collectively, the analysis detected two Aroclors and 12 PCB
congeners. Table 16 summarizes detected PCBs, frequency of detection, range of concentrations, and
the location of the maximum concentration.
Table 16: Bottomland Drainage Ditch Surface Water Data Summary - PCBs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Aroclors via method SW8082. Concentration units are
Aroclor 1254
n Mg/L
5%
0.15
0.15
SW-7
Aroclor 1268
85%
0.062
17
SW-7
PCB Congeners via method E1668. Concentration units
PCB-105
are in nj
100%
S/L
0.0365
31.6
SW-7
PCB-106/118
100%
0.129
99.4
SW-7
PCB-114
50%
0.105
1.74
SW-7
PCB-123
50%
0.102
1.38
SW-7
PCB-126
50%
0.0867
0.873
SW-7
PCB-156
75% -
0.131
11.7
SW-7
PCB-157
75%
0.0284
2.94
SW-7
PCB-167
75%
0.128
7.42
SW-7
PCB-169
75%
0.0299
0.86
SW-7
PCB-189
100%
0.0459
11.6
SW-7
PCB-77
75%
0.0592
5.47
SW-7
PCB-81
50%
0.0663
1.34
SW-7
Dioxins/Furans
Six surface water samples were analyzed for dioxin/furan congers, and four surface water samples for
dioxin-like PCB congeners. A representative 2,3,7,8-TCDD toxicity equivalency quantity (TEQ) was
calculated for each sample. Using the TEQ system, each of the dioxin/furan congeners and dioxin-like
PCB congeners are assigned a Toxic Equivalency Factor (TEF) based on the congener's toxicity relative
to 2,3,7,8-TCDD, with the toxicity of TCDD being equal to 1.0. The concentration of each dioxin/furan
or dioxin-like PCB congener is multiplied by its respective TEF and the results are summed. The sum of
the products of the concentrations multiplied by the appropriate TEF is known as the TEQ of the sample.
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Table 17 summarizes detected dioxins and furans, frequency of detection, range of concentrations, and
the location of the maximum concentration.
55
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 17: Bottomland Drainage Ditch Surface Water Data Summary - Dioxins/Furans
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Dioxins/Furans via method E1613. Concentration units
1,2,3,4,6,7,8-HpCDD
are in nj
83%
5/L
0.0156
0.493
SW-7
1,2,3,4,6,7,8-HpCDF
100%
0.0134
5.17
SW-7
1,2,3,4,7,8,9-HpCDF
83%
0.00681
0.181
SW-7
1,2,3,4,7,8-HxCDD
17%
0.00604
0.00604
SW-7
1,2,3,4,7,8-HxCDF
100%
0.00394
1.36
SW-7
1,2,3,6,7,8-HxCDD
17%
0.00726
0.00726
SW-7
1,2,3,6,7,8-HxCDF
83%
0.00773
0.279
SW-7
1,2,3,7,8,9-HxCDD
17%
0.00449
0.00449
SW-7
1,2,3,7,8,9-HxCDF
83%
0.0016
0.0492
SW-7
1,2,3,7,8-PeCDD
17%
0.00181
0.00181
SW-7
1,2,3,7,8-PeCDF
83%
0.00286
0.152
SW-7
2,3,4,6,7,8-HxCDF
83%
0.0136
0.391
SW-7
2,3,4,7,8-PeCDF
83%
0.00482
0.17
SW-7
2,3,7,8-TCDF
67%
0.013
0.0694
SW-7
HpCDD
83%
0.0377
1.1
SW-7
HpCDF
100%
0.0259
7.25
SW-7
HxCDD
83%
0.012
0.116
SW-7
HxCDF
100%
0.0205
4.93
SW-7
OCDD
100%
0.0574
8.86
SW-7
OCDF
100%
0.00997
4.33
SW-7
PeCDD
50%
0.00549
0.0281
SW-7
PeCDF
100%
0.0254
1.5
SW-7
TCDD
17%
0.00749
0.00749
SW-7
TCDF
100%
0.0113
0.532
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
100%
0.0107
1.02
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
100%
0.00404
0.372
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) -
Mammal
100%
0.00662
0.457
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
100%
0.00451
0.522
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
100%
0.0039
0.366
SW-7
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
100%
0.00338
0.338
SW-7
Total 2,3,7,8-TCDD TEQ (PCB) - Bird
100%
0.000142
0.00646
SW-7
Total 2,3,7,8-TCDD TEQ (PCB) - Fish
100%
0.00624
0.502
SW-7
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
100%
0.00324
0.119
SW-7
56
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Record of Decision
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Summary of Remedial Alternative Selection
September 2017
Surface Water Summary
Preliminary Remediation Goals (PRGs) were developed during the human health and ecological risk
assessments, and were updated in the Feasibility Study.4 Table 18 lists sample locations that had at least
one contaminant that exceeded a PRG concentration in WBA drainage ditch surface water. Figure 18
highlights the sampling locations which had Aroclor 1268 and/or dioxin/furan concentrations that
exceeded PRGs.
Table 18: Bottomland Drainage Ditch Surface Water Data - Sample Results that Exceeded a PRG
Site Area
Location
ID
Arodor
1268
Total 2,3,7,8-
TCDD
TEQ
(dioxin/furan)
Mammals
Total
2,3,7,8-
TCDD
TEQ
(PCB)
Mammals
Preliminary Remediation Goal (PRGs):
0.44
0.0000087
0.0000095
Central Drainage Ditch
SW-07
17 B
0.000338
0.000119
Central Drainage Ditch
SW-09
2.4 B
NA
NA
Central Drainage Ditch
SW-10
3 B
NA
NA
Central Drainage Ditch
SW-10
7.6 B
NA
NA
Central Drainage Ditch
SW-13
ND
0.0000737
NA
Central Drainage Ditch
SW-15
ND
0.000012
NA
Eastern Drainage Ditch
SW-17
1.7
NA
NA
Eastern Drainage Ditch
SW-24
0.86 J
NA
NA
Eastern Drainage Ditch
SW-40
2.3
NA
NA
Western Drainage Ditch
SW-11
1.6
0.0000603
5.61E-07
Western Drainage Ditch
SW-12
0.21 J
0.0000524
0.00000016
Western Drainage Ditch
SW-28
3.7
NA
NA
Notes:
Results are expressed in the concentration of micrograms per liter (ng/L)
Only samples that had a concentration that exceeded at least one PRG are included in this table.
B = blank contamination. The analyte was found in an associated blank as well as in the sample
J = estimated concentration
NA = not analyzed
ND = was not detected above the laboratory reporting limit of 1
Bold value exceeds PRG
4More information about PRGs can be found in Section 7.0, Summary of Site Risks.
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September 2017
Figure 18: Locations where constituents in Wooded Bottomland Drainage ditch surface water exceed a Human Health PRG
58
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.2.2 Storm Water
Storm water samples were collected from seven locations in the WBA drainage ditches during extreme
rain events in 2006. As shown in Figure 19, the sample locations were in the western, central and eastern
ditches. All three ditches flow to the Cape Fear River. An off-site laboratory analyzed the samples for
VOCs, SVOCs, inorganics, pesticides, dioxins and water quality criteria.
Table 19 through Table 24 summarize storm water results. With the exception of VOCs, a broad range
of constituents was present in storm water in the WBA drainage ditches.
Water Quality Parameters
Seven storm water samples were collected from the WBA drainage ditches and analyzed for hardness,
TSS and pH; and four storm water samples were analyzed for TOC. Table 19 summarizes detected
water quality parameters, frequency of detection, range of concentrations, and the location of the
maximum concentration.
Table 19: Bottomland Drainage Ditch Storm Water Data Summary - Water Quality Criteria
Minimum
Maximum
Max
Analyte
FOD%
Cone.
Cone.
location
Water Quality Parameters
Method E130.2. Concentration units are in iig/L
Hardness, Total as CaCCh
100%
20,200
316,000
SW-19
Method E160.2. Concentration units are in iig/L
Total Suspended Solids
100%
3,200
452,000
SW-8
Method SW9040B. No units.
PH
100%
7
8
SW-8
Method SW9060. Concentration units are in ng/L
Total Organic Carbon
100%
1,900
7,600
SW-4
59
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
VOCs and SVOCs
Eight storm water samples were collected from the WBA drainage ditches and analyzed for VOCs and
SVOCs. VOCs were not detected. Collectively, the samples contained four detected SVOCs. The four
SVOCs were present at concentrations greater than during normal flow conditions. For example, the
maximum concentration of bis(2-ethylhexyl)phthalate during a non-storm event was 2.7 |ig/L compared
to 9.4 |ig/L during the storm event. Table 20 includes a summary of detected SVOCs in storm water,
frequency of detection, range of concentrations, and the location of the maximum concentration.
Table 20: Bottomland Drainage Ditch Storm Water Data Summary - SVOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
SVOCs via method SW8270. Concentration units are in iig/L
bis(2-ethylhexyl)phthalate
25%
1.7
9.4
SW-5
Fluoranthene
13%
2.1
2.1
SW-8
Phenanthrene
13%
1.3
1.3
SW-8
Pyrene
13%
1.5
1.5
SW-8
60
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Sixteen storm water samples were collected from the WBA drainage ditches and analyzed for
inorganics. Some inorganics had lower concentrations than during normal flow events, while others had
higher concentrations. The maximum concentration of mercury detected in the storm event was 3.5
times higher than during normal flow conditions. Table 21 includes a summary of detected inorganics in
storm water, frequency of detection, range of concentrations, and the location of the maximum
concentration.
Table 21: Bottomland Drainage Ditch Storm Water Data Summary - Inorganics
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Inorganics via method SW6010. Concentration units ar
aluminum
e in iig/L
69%
202
8,010
SW-16
barium
100%
29.3
111
SW-5
calcium
100%
17,300
101,000
SW-19
chromium
63%
8
13
SW-4
cobalt
6%
2.3
2.3
SW-5
copper
50%
7.6
13.5
SW-4
iron
100%
237
7,540
SW-16
lead
50%
4.7
9.2
SW-4
magnesium
100%
1,180
14,600
SW-19
manganese
100%
27.4
234
SW-4
nickel
63%
5
11
SW-4
potassium
100%
1,870
21,100
SW-5
sodium
100%
9,190
3,040,000
SW-5
vanadium
75%
11.1
24.3
SW-16
zinc
100%
6
218
SW-4
Mercury via method SW7470. Concentration units are in ng/L
mercury | 88% 0.43 81.8 | SW-4
61
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Record of Decision
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Summary of Remedial Alternative Selection
September 2017
Pesticides
Eight storm water samples were collected from the WBA drainage ditches and analyzed for pesticides.
Collectively, the samples contained three detected pesticides. The concentrations of the pesticides were
slightly less than the concentrations of the same pesticides detected during non-storm events. Table 22
summarizes detected pesticides in storm water, frequency of detection, range of concentrations, and the
location of the maximum concentration.
Table 22: Bottomland Drainage Ditch Storm Water Data Summary - Pesticides
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Pesticides via method SW8081. Concentration units an
4,4'-DDD
b in )ig/L
13%
0.02
0.02
SW-5
4,4'-DDT
13%
0.03
0.03
SW-5
endrin aldehyde
25%
0.023
0.03
SW-5
PCBs
Eight storm water samples were collected from the WBA drainage ditches for Aroclor 1268 and PCB
congeners. Table 23 summarizes detected PCBs in storm water, frequency of detection, range of
concentrations, and the location of the maximum concentration.
Table 23: Bottomland Drainage Ditch Storm Water Data Summary - PCBs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Arodors via method SW8082. Concentration units are in ng/L
Aroclor 1268 88% 0.1 6.3 SW-4
PCB Congeners via method E1668. Concentration units
PCB-105
are in nj
100%
S/L
0.104
13.7
SW-14
PCB-106/118
100%
0.0545
33.6
SW-14
PCB-114
63%
0.109
0.876
SW-14
PCB-123
63%
0.0785
0.461
SW-4
PCB-126
63%
0.0889
0.352
SW-14
PCB-156
75%
0.0499
5.12
SW-14
PCB-157
63%
0.121
1.08
SW-14
PCB-167
63%
0.676
2.96
SW-14
PCB-169
63%
0.111
0.552
SW-4
PCB-189
88%
0.0721
5.12
SW-4
PCB-77
63%
0.26
1.26
SW-4
PCB-81
63%
0.0553
0.368
SW-14
62
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Dioxins/Furans
Eight storm water samples were collected from the WBA drainage ditches and analyzed for dioxin/furan
congers and dioxin-like PCB congeners. A representative 2,3,7,8-TCDD toxicity equivalency quantity
(TEQ) was calculated for each sample. Using the TEQ system, each of the dioxin/furan congeners and
dioxin-like PCB congeners are assigned a Toxic Equivalency Factor (TEF) based on the congener's
toxicity relative to 2,3,7,8-TCDD, with the toxicity of TCDD being equal to 1.0. The concentration of
each dioxin/furan or dioxin-like PCB congener is multiplied by its respective TEF and the results are
summed. The sum of the products of the concentrations multiplied by the appropriate TEF is known as
the TEQ of the sample.
The results for 2,3,7,8-TCDD TEQs were similar to the concentrations detected in non-storm event
surface water. Table 24 summarizes detected dioxins/furans in storm water, frequency of detection,
range of concentrations, and the location of the maximum concentration.
Table 24: Bottomland Drainage Ditch Storm Water Data Summary - Dioxins/Furans
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Dioxins/Furans via method E1613. Concentration units
1,2,3,4,6,7,8-HpCDD
are in ni
75%
e/L-
0.0148
0.611
SW-8
1,2,3,4,6,7,8-HpCDF
88%
0.0182
5.83
SW-4
1,2,3,4,7,8,9-HpCDF
63%
0.0299
0.253
SW-4
1,2,3,4,7,8-HxCDD
25%
0.0102
0.0159
SW-4
1,2,3,4,7,8-HxCDF
88%
0.00787
1.74
SW-4
1,2,3,6,7,8-HxCDD
25%
0.0145
0.0155
SW-8
1,2,3,6,7,8-HxCDF
63%
0.0289
0.37
SW-4
1,2,3,7,8,9-HxCDD
25%
0.0121
0.015
SW-8
1,2,3,7,8,9-HxCDF
75%
0.00256
0.0741
SW-4
1,2,3,7,8-PeCDF
75%
0.00516
0.268
SW-4
2,3,4,6,7,8-HxCDF
88%
0.00375
0.422
SW-4
2,3,4,7,8-PeCDF
75%
0.00569
0.247
SW-4
2,3,7,8-TCDF
63%
0.0177
0.149
SW-4
HpCDD
75%
0.0363
3.05
SW-8
HpCDF
88%
0.0354
8.27
SW-4
HxCDD
75%
0.00373
0.316
SW-8
HxCDF
100%
0.0119
5.5
SW-4
OCDD
100%
0.045
9.07
SW-8
OCDF
88%
0.0184
4.69
SW-4
PeCDD
38%
0.00625
0.0255
SW-4
PeCDF
88%
0.045
1.57
SW-4
TCDF
88%
0.0355
0.735
SW-4
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
100%
0.0279
0.884
SW-4
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
100%
0.0117
0.488
SW-4
63
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
, T ,,,J. _- ^
m ' ,F i liiiip ifeti ii&m
¦ ¦ ¦
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) -
Mammal
100%
0.0163
0.491
SW-4
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
100%
0.0154
0.759
SW-4
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
100%
0.0114
0.486
SW-4
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
100%
0.00975
0.44
SW-4
Total 2,3,7,8-TCDD TEQ (PCB) - Bird
100%
0.0000277
0.00239
SW-14
Total 2,3,7,8-TCDD TEQ (PCB) - Fish
100%
0.0122
0.131
SW-14
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
100%
0.00633
0.00505
SW-4
Summary
Figure 19 illustrates sampling locations that had concentrations of contaminants in storm water that
exceeded PRGs.
Figure 19: Location of storm water samples that had a concentration that exceeds a surface water PRG for at least one COC
Storm water
sample
concentration
exceeds RGO for
at least one COC
SW-05
64
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
5.6.2.3 Cape Fear River and Livingston Creek
Surface water samples were collected from multiple locations in the Cape Fear River and Livingston
Creek during 2002 through 2005. Table 25 through Table 29 include summary- statistics for detected
constituents in these off-site surface waters, frequency of detection, range of concentrations, and the
location of the maximum concentration. Figure 20 illustrates the sampling locations.
Table 25: Cape Fear River and Livingston Creek Surface Water Data Summary - Water Quality Parameters
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Water Quality Parameters
Method E130.2. Concentration units are in ng/L
Hardness, Total as CaCC>3
100%
20,200
316,000
SW-19
Method E160.2. Concentration units are in (ig/L
Total Suspended Solids 100% 3,200 452,000 SW-8
Method SW9040B. No units.
pH 100% 7 7.4 IP-SW
Table 26: Cape Fear River and Livingston Creek Surface Water Data Summary - VOCs and SVOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
VOCs via method SW8260. Concentration units are in \i
acetone
g/L
9%
2.5
2.5
WRIGHT-SW
methylene chloride
27%
10
10
LCP001, 5 & 6
toluene
9%
0.26
0.26
WRIGHT-SW
SVOCs via method SW8270. Concentration units are in ng/L
bis(2-ethylhexyl)phthalate 36% 3.1 3.4 | RIVER-UP-2
65
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 27: Cape Fear River and Livingston Creek Surface Water Data Summary Inorganics
Analyte
FOD%
Minimum
Cone
Maximum
Cone.
Max location
Inorganics via method SW6010. Concentration units are in
Mg/L
aluminum
82%
123
1,320
RIVER-DN-1
antimony
45%
0.74
6.1
RIVER-REF
barium
100%
25.7
40
LCP007
calcium
100%
6,200
11,800
WRIGHT-SW
cobalt
9%
2
2
RIVER-REF
iron
100%
538
1,520
RIVER-DN-1
lead
45%
0.78
2
RIVER-REF
magnesium
100%
2,190
2,940
RIVER-REF
manganese
100%
21.7
110
LCP007
potassium
100%
2,450
4,500
LCP007
selenium
9%
3.7
3.7
RIVER-REF
sodium
100%
7,590
31,000
LCP007
strontium
100%
44
54
LCP007
thallium
55%
2.8
4.7
RIVER-DN-2
titanium
100%
6.9
11
LCP006& LCP007
vanadium
64%
2.6
11
LCP007
zinc
100%
5.8
12
LCP007
Mercury via method E1631. Concentration units are in |ig/L
mercury 100% 0.0022 | 0.00634 SW-3
66
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Record of Decision , Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
Table 28: Cape Fear River and Livingston Creek Surface Water Data Summary - Pesticides
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Pesticides via method SW8081. Concentration units ar
4,4'-DDD
e in iig/L
20%
0.00154
0.0362
IP-SW
4,4'-DDE
20%
0.00136
0.0228
IP-SW
4,4'-DDT
30%
0.000952
0.00388
RIVER-REF
acetone
9%
2.5
2.5
WRIGHT-SW
Aldrin
20%
0.00101
0.00237
IP-SW
alpha-chlordane
20%
0.00251
0.00282
WRIGHT-SW
dieidrin
40%
0.000366
0.00147
WRIGHT-SW
Endosulfan 1
30%
0.000812
0.0043
IP-SW
Endosulfan II
20%
0.00113
0.00148
IP-SW
Endosulfan sulfate
30%
0.0019
0.00176
RIVER-UP-2
endrin
30%
0.000495
0.00843
IP-SW
gamma-chlordane
40%
0.000629
0.0112
RIVER-DN-1
heptachlor
20%
0.000754
0.0194
RIVER-REF
Table 29: Cape Fear River and Livingston Creek Surface Water Data Summary - Aroclors and Dioxins/Furans
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Aroclors via method SW8082. Concentration units are in ng/L
Aroclor 1268 14% 0.0423 0.0423 RIVER-UP-1
Dioxins/Furans via method E1613. Concentration unit!
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
are in p
100%
8.05
8.05
IP-SW
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
100%
6.89
6.89
IP-SW
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) -
Mammal
100%
6.27
6.27
IP-SW
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
100%
7.66
7.66
IP-SW
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
100%
6.87
6.87
IP-SW
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
100%
5.88
5.88
IP-SW
Total 2,3,7,8-TCDD TEQ (PCB) - Bird
100%
0.0196
0.0196
IP-SW
Total 2,3,7,8-TCDD TEQ (PCB) - Fish
100%
0.391
0.391
IP-SW
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
100%
0.391
0.391
IP-SW
67
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Figure 20: Surface water result for COCs in Cape Fear River and Livingston Creek
Iw. »¦ Inti,-
wwe SB~ror-
ti»Li tiikmr rag
5.6.3 Sediment
During 2002 through 2009, 130 sediment samples were collected from multiple locations in the WBA
drainage pathways, the storm sewers, the Cape Fear River and Livingston Creek. The following
subsections discuss the data for each of the three areas.
5.6.3.1 WBA Drainage Pathways Sediment
The WBA drainage pathways are comprised of eastern, central and western channels. Sediment samples
were collected and analyzed for VOCs, SVOCs, inorganics, pesticides, PCBs and dioxins/furans.
Chemicals from each category were detected.
Table 30 summarizes solids, moisture, TOC and pH, including value ranges and location of the
maximum value.
68
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 30: Wooded Bottomland Drainage Pathway Sediment Data Summary - Characterization
Minimum
Maximum
Analyte
FOD%
Cone.
Cone.
Max location
Sediment Characterization
Method E160.3
Total Solids
100%
74.66%
78.79%
WSED-41
Method SM2540G
Percent Solids
100%
73.90%
78.20%
WSED-41
Method E160.3M
Percent Moisture
100%
14.50%
54.00%
WSED-20-D0.5-1
Method 9045
pH
100%
6.8
9.1
WSED-17-D0.5-1
Method 9060. Concentration units are in mg/kg.
Total Organic Carbon
89%
1,400
43,000
WSED-25-D0-0.5
VOCs
Fifty-four sediment samples were collected from the WBA drainage ditches and analyzed for VOCs.
Collectively, the samples contained 12 detected VOCs. Table 31 summarizes detected VOCs, frequency
of detection, concentration ranges and location of the maximum concentration.
Table 31: Wooded Bottomland Drainage Pathway Sediment Data Summary - VOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
VOCs via method SW8260. Concentration units are in |i£/
*g-
1,3-Dichlorobenzene
9%
3.4
47
WSED-4-D1-2
1,4-Dichlorobenzene
7%
3.2
76
WSED-29-D0.5-1
2-butanone
13%
6.2
18
WSED-20-D0.5-1
acetone
17%
7.8
200
WSED-9-D0-0.5
bromomethane
2%
6.1
6.1
WSED-20-D0.5-1
carbon disulfide
6%
1.3
8.4
WSED-20-D0.5-1
chlorobenzene
7%
0.87
7.3
WSED-29-D0.5-1
chloroform
4%
2.1
4.6
WSED-1-D1-2
cis-l,2-dichloroethene
2%
2.3
2.3
WSED-7-D0.5-1
toluene
13%
0.89
2.7
WSED-20-D0.5-1
trichloroethene (TCE)
4%
0.88
1.6
WSED-7-D0.5-1
trichlorofluoromethane
21%
1.8
5.5
WSED-20-D0.5-1
69
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
SVOCs
Fifty-seven sediment samples were collected from the WBA drainage ditches and analyzed for SVOCs.
Collectively, the samples contained 30 detected SVOCs. Table 32 summarizes detected SVOCs,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 32: Wooded Bottomland Drainage Pathway Sediment Data Summary - SVOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
SVOCs via method SW8270. Concentration units are in mg/kg.
2-methylnaphthalene
2%
0.085
0.085
HC-16-SS
3,3'-dichlorobenzidine
4%
0.1
1.3
WSED-9-D0.5-1
3+4-methylphenol
5%
0.15
0.15
HC-16-SS
3-nitroaniline
2%
0.031
0.031
WSED-5-D1-2
4-methylphenol
3%
0.024
0.024
WSED-40-SED
acenaphthene
9%
0.0026
0.1
WSED-30-D0.5-1
acenaphthylene
2%
0.028
0.028
WSED-5-D0-0.5
anthracene
7%
0.036
0.76
WSED-5-D0-0.5
benzo(a)anthracene
33%
0.065
2.1
WSED-5-D0-0.5 & WSED-09-D0.5-1
benzo(a)pyrene
19%
0.0087
1.5
WSED-9-D0.5-1
benzo(b)fluoranthene
19%
0.022
1.7
WSED-5-D0-0.5 & WSED-09-D0.5-1
benzo(g,h,i)perylene
19%
0.0094
0.75
WSED-9-D0.5-1
benzo(k)fluoranthene
18%
0.042
1.3
WSED-9-D0.5-1
bis(2-ethylhexyl)phthalate
32%
0.056
0.63
WSED-9-D0.5-1
butyl benzyl phthalate
7%
0.045
0.36
WSED-24-D0.5-1
caprolactam
8%
0.02
0.02
WSED-40-SED
carbazole
4%
0.047
0.075
WSED-30-D0.5-1
chrysene
35%
0.013
2.7
WSED-5-D0-0.5
dibenzo(a,h)anthracene
7%
0.12
0.28
WSED-15-D0-0.5
dibenzofuran
4%
0.08
0.097
WSED-5-D0-0.5
diethyl phthalate
25%
0.032
0.3
WSED-9-D0.5-1
dimethyl phthalate
2%
0.096
0.096
WSED-10-D0-0.5
fluoranthene
37%
0.0083
6.7
WSED-5-D0-0.5
fluorene
7%
0.0043
0.24
WSED-5-D0-0.5
hexachlorobenzene
44%
0.027
1.3
WSED-9-D0.5-1
hexachloroethane
4%
0.036
0.18
WSED-2-D0-0.5
ideno(l,2,3-cd)pyrene
21%
0.0078
0.72
WSED-9-D0.5-1
naphthalene
4%
0.029
0.14
HC-16-SS
phenanthrene
30%
0.014
3.5
WSED-2-D0-0.5
pyrene
37%
0.005
6
WSED-5-D0-0.5
70
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Fifty-seven sediment samples were collected from the WBA drainage ditches and analyzed for
inorganics. Thirty more samples were collected and analyzed for only mercury. Collectively, the
samples contained 25 detected inorganics and mercuric compounds. Many inorganics are naturally
occurring. Table 33 summarizes detected inorganics and mercuric compounds, frequency of detection,
concentration ranges and location of the maximum concentration.
Table 33: Wooded Bottomland Drainage Pathway Sediment Data Summary - Inorganics
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Inorganics via method SW6010. Concentration units are in mg/kg.
aluminum
95%
355
30,000
HC-16-SS
antimony
5%
0.3
0.47
WSED-4-D1-2
arsenic
64%
0.52
6.8
WSED-20-D0.5-1
barium
95%
1.4
76
HC-16-SS
beryllium
42%
0.069
0.93
WSED-20-D0.5-1
cadmium
49%
0.12
2
WSED-20-D0.5-1
calcium
95%
353
42,500
WSED-42
chromium
93%
1.2
55.4
WSED-20-D0.5-1
cobalt
74%
0.28
5.4
WSED-15-D0.5-1
copper
81%
0.26
13
HC-16-SS
iron
95%
403
32,100
WSED-20-D0.5-1
lead
93%
0.67
64.3
WSED-9-D0.5-1
magnesium
95%
48.8
3,070
WSED-20-D0.5-1
manganese
95%
4
208
WSED-30-D0-0.5
nickel
88%
0.56
23.9
WSED-10-D0-0.5
potassium
93%
58
2,890
WSED-20-D0.5-1
silver
2%
1.8
1.8
WSED-9-D0.5-1
sodium
82%
91.4
16,000
HC-16-SS
thallium
11%
0.35
0.8
WSED-4-D1-2
vanadium
95%
1.2
66
HC-16-SS
zinc
95%
3.1
262
WSED-9-D0.5-1
Mercury via method SW7471. Cone
mercury
entration
94%
units are in m
0.038
g/kg.
126WSED-16-D0.5-1
Mercury via method SW1630. Cone
methylmercury
entration
100%
units are in m
0.00058
g/k§.
0.00164 WSED-40
Mercury via method SW1631. Cone
mercury
entration
100%
units are in m
0.471
g/kg.
0.635
WSED-42
mercury fraction 1 bloom ES&T
100%
0.0095
0.015
WSED-41 & 42
mercury fraction 5 bloom ES&T
100%
0.0315
0.144
WSED-42
71
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Fifty-seven sediment samples were collected from the WBA drainage ditches and analyzed for
pesticides. Collectively, the samples contained 19 detected pesticides. Table 34 summarizes detected
pesticides, frequency of detection, concentration ranges and location of the maximum concentration.
Table 34: Wooded Bottomland Drainage Pathway Sediment Data Summary - Pesticides
Minimum
Maximum
Analyte
FOD%
Cone.
Cone.
Max location
Pesticides via method SW8081. Concentration units are in mg/kg.
4,4'-DDD
46%
0.00023
1.1
WSED-9-D0.5-1
4,4'-DDE
32%
0.00038
0.052
WSED-13-D0-0.5
4,4'-DDT
49%
0.0019
7.9
WSED-9-D0.5-1
aldrin
44%
0.000514
0.17
WSED-9-D0.5-1
alpha-BHC
20%
0.00034
0.064
WSED-41
alpha-chlorodane
4%
0.00153
0.00153
WSED-4-D0-0.5
beta-BHC
49%
0.011
0.88
WSED-9-D0.5-1
delta-BHC
26%
0.00023
0.14
WSED-9-D0.5-1
dieldrin
26%
0.00038
0.28
WSED-9-D0.5-1
endosulfan 1
28%
0.00032
0.01
WSED-13-D0-0.5
endosulfan II
46%
0.00016
0.024
WSED-20-D0-0.5
endosulfan sulfate
28%
0.00033
0.042
WSED-13-D0-0.5
endrin
42%
0.00045
0.54
WSED-9-D0.5-1
endrin aldehyde
57%
0.0011
2.6
WSED-9-D0.5-1
gamma-BHC
35%
0.0009
0.19
WSED-9-D0.5-1
gamma-chlordane
11%
0.000944
0.00218
WSED-4-D0-0.5
heptachlor
12%
0.000677
0.012
WSED-10-D0-0.5
heptachlor epoxide
35%
0.00073
0.014
WSED-27-D0.5-1
methoxychlor
17%
0.00055
0.019
WSED-27-D0.5-1
72
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
PCBs
Seventy-seven sediment samples were collected from the WBA drainage ditches and analyzed for PCBs.
Collectively, the samples contained four detected Aroclors and 13 PCB congeners. Table 35 summarizes
detected PCBs, frequency of detection, concentration ranges and location of the maximum
concentration.
Table 35: Wooded Bottomland Drainage Pathway Sediment Data Summary - PCBs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Aroclors via method SW8082. Cone
Aroclor 1016
entration
1%
units are in m
1.9
s/kg-
1.9
WSED-13-D0-0.5
Aroclor 1248
3%
0.051
1.6
WSED-11-D0.5-1
Aroclor 1254
42%
0.0084
14
WSED-102705-001
Aroclor 1268
98%
0.042
1,500
WSED-9-D0.5-1
PCBs via method E1668. Concentra
PCB-105
:ion units
8%
are in ng/kg.
7.14
88,700
WSED-9-D0.5-1
PCB-106/118
100%
18.6
247,000
WSED-9-D0.5-1
PCB-114
67%
7.01
4,830
WSED-9-D0.5-1
PCB-118
90%
1.25
137
WSED-2-D1-2
PCB-123
67%
8.36
2,610
WSED-9-D0.5-1
PCB-126
67%
5.84
1,990
WSED-9-D0.5-1
PCB-156
83%
31.3
28,300
WSED-9-D0.5-1
PCB-157
83%
5.49
5,810
WSED-9-D0.5-1
PCB-167
83%
23.1
15,200
WSED-9-D0.5-1
PCB-169
75%
6.47
1,510
WSED-9-D0.5-1
PCB-189
83%
38.1
24,700
WSED-9-D0.5-1
PCB-77
83%
15.9
21,900
WSED-9-D0.5-1
PCB-81
67%
5.49
3,860
WSED-9-D0.5-1
Dioxins/Furans
Twenty-two sediment samples were collected from the WBA drainage ditches and analyzed for
dioxins/furans.
73
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Record of Decision Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
Table 36 summarizes detected dioxins/furans, frequency of detection, concentration ranges and location
of the maximum concentration.
74
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 36: Wooded Bottomland Drainage Pathway Sediment Data Summary - Dioxins/Furans
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Dioxins/Furans via methods E1613 and SW8290. Conce
1,2,3,4,6,7,8- H pCD D
ntration
100%
units are in
0.705
ng/kg.
852
WSED-9D0.5-1
1,2,3,4,6,7,8-HpCDF
95%
1.41
34,300
WSED-2-D1-2
1,2,3,4,7,8,9-HpCDF
86%
0.736
1,720
WSED-9D0.5-1
1,2,3,4,7,8-HxCDD
59%
0.298
42
WSED-9D0.5-1
1,2,3,4,7,8-HxCDF
91%
0.552
9,950
WSED-9D0.5-1
1,2,3,6,7,8-HxCDD
68%
0.31
31.5
WSED-9D0.5-1
1,2,3,6,7,8-HxCDF
86%
0.737
2,170
WSED-9D0.5-1
1,2,3,7,8,9-HxCDD
68%
0.289
20.9
WSED-9D0.5-1
1,2,3,7,8,9-HxCDF
75%
2.29
360
WSED-9D0.5-1
1,2,3,7,8-PECDD
32%
0.243
11.1
WSED-9D0.5-1
1,2,3,7,8-PeCDF
86%
0.405
747
WSED-9D0.5-1
2,3,4,6,7,8-HxCDF
86%
0.815
3,140
WSED-9D0.5-1
2,3,4,7,8-PeCDF
86%
0.606
1,120
WSED-9D0.5-1
2,3,7,8-TCDD
32%
0.14
3.78
WSED-9D0.5-1
2,3,7,8-TCDF
86%
0.341
265
WSED-9D0.5-1
HpCDD
100%
1.87
2,460
WSED-9D0.5-1
HpCDF
100%
0.983
50,200
WSED-2-D1-2
HxCDD
100%
1.02
781
WSED-9D0.5-1
HxCDF
100%
0.906
37,000
WSED-9D0.5-1
OCDD
100%
37.7
10,500
WSED-26D0.5-1
OCDF
84%
1.4
34,500
WSED-9D0.5-1
PeCDD
27%
0.415
59.3
WSED-2-D1-2
PeCDF
91%
0.388
12,000
WSED-9D0.5-1
TCDD
68%
0.102
38.6
WSED-9D0.5-1
TCDF
91%
0.539
3,510
WSED-9D0.5-1
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
100%
0.428
1,650
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
100%
0.384
1,480
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) -
Mammal
100%
0.38
1,450
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
100%
0.397
1,640
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
100%
0.382
1,480
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
100%
0.349
1,430
WSED-2-D1-2
Total 2,3,7,8-TCDD TEQ (PCB) - bird
100%
0.00152
0.82
WSED-28-D0-0.5
Total 2,3,7,8-TCDD TEQ (PCB) - fish
100%
0.0303
56.5
WSED-27-D0.5-1
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
100%
0.0303
20.9
WSED-28-D0-0.5
75
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Summary
Mercury and Aroclor 1268 are the contaminant that pose the greatest risks in the WBA sediments.5
Figure 21 illustrates the extent of mercury and Aroclor 1268 in W sediment. Mercury concentrations
ranged from non-detect to 126 mg/kg. Aroclor 1268 concentrations in the wooded bottomland sediments
ranged from non-detect to 1,500 mg/kg.
Figure 21: Wooded Bottomland Drainage Pathways Sediment Sample Locations
5 See Section 7.0 for risk assessment information.
76
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.3.2 Storm Water Sewer System Sediment
The storm water sewer system currently drains the UPA rainfall and storm water to the UNPA retention
basins. Historically it may have collected spilled chemicals. The water flows through the sewer system
and is treated prior to discharge to IP for further treatment. After treatment, it is discharged to the Cape
Fear River. The sediment remaining in the sewer system was sampled during the EE/CA-RI.
VOCs
Twelve sediment samples were collected from the storm water sewer system and analyzed for VOCs.
Collectively, the samples contained 10 detected VOCs. Table 37 summarizes detected VOCs, frequency
of detection, concentration ranges and location of the maximum concentration.
Table 37: Storm Sewer Sediment Data Summary - VOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
VOCs via method SW8260. Concc
1,2-dichloroethene (total)
mtration
25%
units are in
2.2
Hg/kg-
27
SED-9-D1-3
acetone
67%
12
200
SED-8-D0-1
carbon disulfide
75%
0.74
1.8
SED-1-1204
carbon tetrachloride
17%
2.9
3.3
SED-9-D1-3
chloroform
17%
0.99
3.5
SED-6-1204
methyl isobutyl ketone
58%
5.2
11
SED-8-D0-1
tetrachloroethene (PCE)
17%
7.6
150
SED-6-1204
trichloroethene (TCE)
25%
1.2
32
SED-9-D1-3
vinyl chloride
17%
1.8
4.5
SED-9-D1-3
xylenes, total
8%
4.2
4.2
SED-6-1204
77
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Record of Decision
LCP-HoItrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
SVOCs
Twelve storm water sewer system sediment samples were collected and analyzed for SVOCs.
Collectively, the samples contained 26 detected SVOCs. Table 38 summarizes detected SVOCs,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 38: Storm Sewer Sediment Data Summary - SVOCs
Minimum
Maximum
Analyte
FOD%
Cone.
Cone.
Max location
SVOCs via method SW8270. Concentration units are in mg/kg.
1,2,4-trichlorobenzene
8%
0.14
0.14
SED-6-1204
1,4-Dichlorobenzene
8%
0.069
0.069
SED-6-1204
3+4-methylphenol
8%
0.063
0.063
SED-1-1204
acenaphthene
25%
0.027
0.063
SED-6-1204
anthracene
33%
0.023
0.35
SED-1-1204
benzo(a)anthracene
58%
0.04
0.29
SED-1-1204
benzo(a)pyrene
42%
0.04
0.17
SED-1-1204
benzo(b)fluoranthene
42%
0.056
0.26
SED-1-1204
benzo(g,h,i)perylene
58%
0.025
0.094
SED-1-1204
benzo(k)fluoranthene
67%
0.035
0.22
SED-1-1204
bis(2-ethylhexyl)phthalate
58%
0.093
1.9
SED-1-1204
butyl benzyl phthalate
42%
0.021
0.11
SED-1-1204
carbazole
17%
0.046
0.1
SED-1-1204
chrysene
67%
0.036
0.41
SED-1-1204
dibenzo(a,h)anthracene
17%
0.022
0.031
SED-9-D0-1
dimethyl phthalate
33%
0.066
0.34
SED-6-1204
di-n-butyl phthalate
17%
0.14
0.74
SED-2-1204
di-n-octyl phthalate
8%
0.066
0.066
SED-1-1204
fluoranthene
67%
0.061
0.62
SED-1-1204
fluorene
25%
0.035
0.056
SED-1&6-1204
hexachlorobenzene
58%
0.027
1.1
SED-6-1204
hexachlorobutadiene
17%
0.053
0.37
SED-6-1204
hexachloroethane
17%
0.066
1.2
SED-6-1204
ideno(l,2,3-cd)pyrene
50%
0.026
0.097
SED-1-1204
phenanthrene
58%
0.044
0.39
SED-1&6-1204
pyrene
67%
0.058
0.59
SED-1-1204
78
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Record of Decision
LCP-HoItrachem Superflmd Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Twelve storm water sewer system sediment samples were collected and analyzed for inorganics and
mercury. Collectively, the samples contained 22 detected inorganics and mercuric compounds. Many
inorganics are naturally occurring. Table 39 summarizes detected inorganics and mercuric compounds,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 39: Storm Sewer Sediment Data Summary - Inorganics
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Inorganics via method SW6010. (
aluminum
loncentr
100%
ation units
1,850
re in mg/kg.
7,630
SED-10-D3-4
antimony
42%
0.33
6.4
SED-2-1204
arsenic
92%
0.61
27.6
SED-2-1204
barium
100%
6.2
85.4
SED-1-1204
beryllium
100%
0.082
0.57
SED-7-D1-2
cadmium
42%
0.11
1.2
SED-1-1204
calcium
100%
1,230
53,100
SED-1-1204
chromium
100%
4.1
94.6
SED-2-1204
cobalt
100%
0.57
14.8
SED-2-1204
copper
100%
0.9
564
SED-2-1204
iron
100%
4,420
. 155,000
SED-2-1204
lead
100%
2.5
27.3
SED-2-1204
magnesium
100%
441
2,860
SED-7-D1-2
manganese
100%
18.7
597
SED-2-1204
nickel
100%
1.6
112
SED-2-1204
potassium
100%
100
2,410
SED-7-D1-2
silver
25%
0.45
5.4
SED-1-1204
sodium
83%
261
4,000
SED-6-1204
thallium
42%
0.34
0.56
SED-7-D0-1
vanadium
100%
4
42.2
SED-2-1204
zinc
100%
10
499
SED-2-1204
Mercury via method SW7471. Concentration units are in mg/kg.
mercury | 100% | 1.4 | 570 | SED-6-1204
79
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Record of Decision
LCP-HoItrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Twelve storm water sewer system sediment samples were collected and analyzed for pesticides.
Collectively, the samples contained 12 detected pesticides. Table 40 summarizes detected pesticides,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 40: Storm Sewer Sediment Data Summary - Pesticides
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Pesticides via method SW8081. C
4,4'-DDD
loncentr
17%
ation units a
0.000508
re in mg/kg.
0.0315
SED-6-1204
4,4'-DDE
25%
0.000615
0.0195
SED-6-1204
4,4'-DDT
42%
0.0158
0.0787
SED-6-1204
aldrin
58%
0.000407
0.0551
SED-6-1204
alpha-chlorodane
50%
0.000487
0.0139
SED-9-D0-1
dieldrin
50%
0.00224
0.0198
SED-9-D1-3
endosulfan 1
25%
0.000681
0.0156
SED-9-D1-3
endosulfan II
50%
0.00133
0.0199
SED-9-D1-3
endosulfan sulfate
8%
0.0379
0.0379
SED-6-1204
endrin
25%
0.00136
0.0323
SED-9-D1-3
gamma-chlordane
58%
0.000553
0.2
SED-6-1204
heptachlor
58%
0.00056
0.235
SED-1-1204
PCBs
Twelve storm water sewer system sediment samples were collected and analyzed for Aroclor 1268.
Table 41 summarizes detected PCBs, frequency of detection, concentration ranges and location of the
maximum concentration.
Table 41: Storm Sewer Sediment Data Summary - Aroclor 1268
Minimum
Maximum
Max
Analyte
FOD%
Cone.
Cone.
location
Aroclor 1268 via method SW8082. Concentration units are in mg/kg.
Aroclor 1268
100%
0.172
21.9
SED-2-1204
80
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.33 Off-site Sediment in the Cape Fear River and Livingston Creek
Twenty-one sediment samples were collected from the Cape Fear River and Livingston Creek. Table 42
summarizes detected moisture content, pH and TOC, frequency of detection, concentration/percentage
ranges and location of the maximum concentration/percentage.
Table 42: Cape Fear River and Livingston Creek Sediment Data Summary - Characterization
Minimum
Maximum
Analyte
FOD%
Cone.
Cone.
Max location
Sediment Characterization
Method E160.3M
Percent Moisture
100%
30%
51.1%
IP-SED3
Method 9045
PH
100%
6.7
6.7
IP-SED1&3
Method 9060. Concentration units are in mg/kg.
Total Organic Carbon
100%
21
109
IP-SED3
VOCs
Twenty-one sediment samples were collected from the Cape Fear River and Livingston Creek and
analyzed for VOCs. Collectively, the samples contained five detected VOCs. Table 43 summarizes
detected VOCs, frequency of detection, concentration ranges and location of the maximum
concentration.
Table 43: Cape Fear River and Livingston Creek Sediment Data Summary - VOCs
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
VOCs via method SW8260. Concentration units are in ng/kg.
acetone
71%
32
4,500
RIVER-REF-4-SED
carbon disulfide
86%
1.3
12
LCP005SD
methyl isobutyl ketone
29%
7.9
41
RIVER-REF-1-SED
styrene
76%
2.1
7.5
RIVER-UP-1-SED
o-xylene
100%
130
130
LCP007SD
81
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
SVOCs
Twenty-one sediment samples were collected from the Cape Fear River and Livingston Creek and were
analyzed for SVOCs. Collectively, the samples contained 14 detected SVOCs. Table 44
includes a summary of detected SVOCs, frequency of detection, concentration ranges and location of the
maximum concentration.
Table 44: Cape Fear River and Livingston Creek Sediment Data Summary - SVOCs
Minimum
Maximum
Analyte
FOD%
Cone.
Cone.
Max location
SVOCs via method SW8270. Concentration units are in mg/kg.
benzo(a)anthracene
24%
0.043
0.067
WRIGHT-SED3
benzo(a)pyrene
10%
0.036
0.078
WRIGHT-SED3
benzo(b)fluoranthene
10%
0.05
0.098
WRIGHT-SED3
benzo(g,h,i)perylene
14%
0.027
0.048
WRIGHT-SED3
benzo(k)fluoranthene
19%
0.042
0.094
WRIGHT-SED3
bis(2-ethylhexyl)phthalate
33%
0.05
0.36
RIVER-UP-1&2-SED
butyl benzyl phthalate
19%
0.042
0.17
WRIGHT-SED3
chrysene
57%
0.041
0.17
WRIGHT-SED3
dibenzo(a,h)anthracene
5%
0.04
0.04
WRIGHT-SED3
fluoranthene
67%
0.038
0.13
RIVER-UP-1-SED; RIVER-REF-1-SED
hexachlorobenzene
10%
0.12
0.37
SITE-2-SED
ideno(l,2,3-cd)pyrene
19%
0.024
0.063
RIVER-UP-1-SED
phenanthrene
14%
0.026
0.065
WRIGHT-SED3
pyrene
76%
0.041
0.13
RIVER-UP-1-SED
82
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Twenty-one sediment samples were collected from the Cape Fear River and Livingston Creek and were
analyzed for for inorganics and mercury. Collectively, the samples contained 27 detected inorganics and
mercuric compounds. Many inorganics are naturally occurring. Table 45 summarizes detected
inorganics and mercuric compounds, frequency of detection, concentration ranges and location of the
maximum concentration.
Table 45: Cape Fear River and Livingston Creek Sediment Data Summary - Inorganics
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Inorganics via method SW60
aluminum
10. Cone
100%
entration un
2,920
its are in mg
26,800
/kg-
RIVER-UP-1-SED
antimony
67%
0.36
4.2
WRIGHT-SED2
arsenic
100%
0.76
64.5
WRIGHT-SED3
barium
100%
16
399
WRIGHT-SED2
beryllium
100%
0.1
1.4
RIVER-UP-1-SED
cadmium
43%
0.14
7.2
WRIGHT-SED3
calcium
100%
676
41,000
LCP007SD
chromium
100%
6.5
34.1
RIVER-UP-1-SED
cobalt
100%
2.1
19.6
RIVER-UP-1-SED
copper
100%
3.4
456
iron
100%
6,740
31,300
RIVER-UP-1-SED
lead
100%
4.3
272
WRIGHT-SED3
magnesium
100%
108
4,100
LCP007SD
manganese
100%
28.1
1,560
RIVER-UP-2-SED
molybdenum
25%
0.8
0.8
LCP007SD
nickel
100%
1.4
14.8
RIVER-UP-1-SED
potassium
100%
94.9
2,400
LCP007SD
selenium
24%
0.57
1.7
RIVER-REF-4-SED
silver
10%
0.059
0.065
WRIGHT-SED3
sodium
14%
170
1,100
LCP002SD
strontium
100%
8.8
140
LCP007SD
thallium
71%
0.47
1.9
RIVER-UP-2-SED
titanium
100%
40
49
LCP001SD
vanadium
100%
6
60.5
RIVER-UP-1-SED
yttrium
100%
6.1
11
LCP001SD
zinc
100%
20
637
WRIGHT-SED2
Mercury via method SW7471. Concentration units are in mg/kg.
mercury 90% 0.024 1.3 LCP001SD
83
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Twenty-one sediment samples were collected from the Cape Fear River and Livingston Creek and were
analyzed for pesticides. Collectively, the samples contained 11 detected pesticides. Table 46 summarizes
detected pesticides, frequency of detection, concentration ranges and location of the maximum
concentration.
Table 46: Cape Fear River and Livingston Creek Sediment Data Summary Pesticides
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Pesticides via method SW80I
4,4'-DDD
SI. Conci
43%
intration un
0.00122
Its are in mgj
0.148
rkg.
WRIGHT-SED3
4,4'-DDE
67%
0.00171
0.0425
WRIGHT-SED3
4,4'-DDT
62%
0.00126
0.0794
WRIGHT-SED2
aldrin
38%
0.000484
0.00786
WRIGHT-SED3
alpha-chlorodane
52%
0.000568
0.0147
WRIGHT-SED3
beta-BHC
25%
0.0027
0.0027
LCP002SD
dieldrin
29%
0.0018
0.0405
WRIGHT-SED3
endosulfan II
10%
0.000649
0.00105
WRIGHT-SED1
endrin
10%
0.0014
0.0073
LCP002SD
gamma-chlordane
38%
0.000855
0.0301
WRIGHT-SED3
heptachlor
10%
0.000918
0.00168
WRIGHT-SED3
PCBs
Seventeen sediment samples were collected from the Cape Fear River and Livingston Creek and were
analyzed for Aroclor 1268. Table 47 summarizes detected PCBs, frequency of detection, concentration
ranges and location of the maximum concentration.
Table 47: Cape Fear River and Livingston Creek Sediment Data Summary - Aroclor 1268
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max location
Aroclor 1268 via method SW
Aroclor 1268
3082. Concentration units are in mg/kg.
65% 0.0043 0.434 SITE-1-SED
84
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Dioxins/Furans
Six sediment samples were collected from the Cape Fear River and Livingston Creek and were analyzed
for dioxins/furans. Table 48 summarizes detected dioxins/furans, frequency of detection, concentration
ranges and location of the maximum concentration.
Table 48: Cape Fear River and Livingston Creek Sediment Data Summary - Dioxins/Furans
Analyte
FOD%
Minimum
Cone.
Maximum
Cone.
Max
location
Dioxins/Furans via methods E1613 and SW8290. Concer
1,2,3,4,6,7,8-HpCDD
tration
100%
jnits are in n
0.84
g/kg-
179
IP-SED3
1,2,3,4,6,7,8-HpCDF
83%
0.38
170
LCP002SD
1,2,3,4,7,8,9-HpCDF
50%
0.405
5
LCP001SD
1,2,3,4,7,8-HxCDD
50%
0.565
1.38
IP-SED3
1,2,3,4,7,8-HxCDF
83%
0.38
31
LCP002SD
1,2,3,6,7,8-HxCDD
50%
1.6
4.26
IP-SED3
1,2,3,6,7,8-HxCDF
67%
0.28
5.4
LCP002SD
1,2,3,7,8,9-HxCDD
67%
2.02
6.8
LCP001SD
1,2,3,7,8-PECDD
33%
0.28
0.47
LCP005SD
1,2,3,7,8-PeCDF
20%
0.31
0.31
LCP007SD
2,3,4,6,7,8-HxCDF
67%
0.563
11
LCP002SD
2,3,4,7,8-PeCDF
50%
0.389
2.3
LCP001SD
2,3,7,8-TCDD
33%
0.171
0.255
IP-SED3
2,3,7,8-TCDF
50%
0.328
1.4
LCP001SD
HpCDD
100%
219
411
IP-SED3
HpCDF
100%
16.2
37
IP-SED3
HxCDD
100%
31
62.9
IP-SED3
HxCDF
100%
6.55
12.5
IP-SED3
OCDD
83%
2,700
7,600
LCP002SD
OCDF
83%
0.78
110
LCP002SD
PeCDD
100%
4.64
5.86
IP-SED3
PeCDF
100%
1.41
2.06
IP-SED3
TCDD
100%
5.78
8.27
IP-SED3
TCDF
100%
2.83
3.49
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
100%
2.23
4.74
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
100%
1.58
4.16
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Mammal
100%
3.03
7.49
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
100%
2.18
4.67
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
100%
1.58
4.15
IP-SED3
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
100%
2.99
7.41
IP-SED3
Total 2,3,7,8-TCDD TEQ (PCB) - bird
100%
0.00241
0.00393
IP-SED3
Total 2,3,7,8-TCDD TEQ (PCB) - fish
100%
0.0482
0.0786
IP-SED3
85
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
1 Total 2,3,7,8-TCDD TEQ (PCB) - Mammal | 100% | 0.0482 | 0.0786 | IP-SED3 |
5.6.4 Wastewater Treatment Solids
During the removal action at IP in 2008-2009, sediments with concentrations of PCBs greater than 50
mg/kg were transported to the site for temporary storage in engineered stockpiles. Samples were
collected of the WWTS at an interval of about one per 1,000 yd3. An off-site laboratory analyzed the
samples for VOCs, SVOCs, metals, pesticides and dioxins. Table 49 through Table 53 summarize the
analytical results of the 21 samples collected (which includes two duplicate samples). The maximum
location indicates the sample ID that had the highest concentration of the analyte. Sample ID
description: for example, ESP-7-071008 means that this was the seventh sample collected of WWTS
entering the engineered stockpile, collected on July 10, 2008.
Notes for Tables in section 5.6.4:
21 samples were analyzed for each analyte. Only analytes detected in at least one sample are included in these tables.
Complete analytical data reports are included in the IP Removal Action Report. _ _ _ _ _ _
Sample ID: Example ESP-6-070808. The 6th sample collected from WWTS placed in the engineered stockpile (ESP); the
sample was collected on July 8,2008. _ __ _
ESP Engineered Stockpile
FOD = frequency of detection = number of samples with a detected concentration of the analyte divided by the total
number of samples analyzed for the analyte. . _
mg/kg = milligrams per kilogram _
ng/kg = nanograms per kilogram _ ____
TCDD = tetrachlorodibenzodioxin _
TCDF = tetrachlorodibenzofuran
pg/kg = micrograms per kilogram
86
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
VOCs
Sixteen VOCs were detected in WWTS placed in the engineered stockpiles (ESP). Table 49 summarizes
VOC sample results, frequency of detection, concentration ranges and location of the maximum
concentration.
Table 49: WWTS Data Summary - VOCs
Analyte
FOD%
minimum
conc.
(|ig/kg)
maximum
conc.
(Mg/kg)
Sample ID of
highest
concentration
1,1-dichloroethene
5%
37
37
ESP-7-071008
1,2,4-trichlorobenzene
57%
1
350
ESP-5-070108
1,3-dichlorobenzene
67%
1.5
480
ESP-8-071608
1,4-dichlorobenzene
62%
0.99
940
ESP-7-071008
2-butanone
19%
9.6
30
ESP-1-061408
acetone
52%
21
370
ESP-1-061408
benzene
10%
1.3
2.6
ESP-6-070808
carbon disulfide
33%
2.4
29
ESP-1-061408
chlorobenzene
43%
0.65
1,100
ESP-7-071008
chloroform
48%
1.1
1,000
ESP-7-071008
cis-l,2-dichloroethene
5%
83
83
ESP-5-070108
dichlorodifluoromethane
5%
3.2
3.2
ESP-10-073108
methyl acetate
19%
3,900
26,000
ESP-5-070108
tetrachloroethene
14%
2.1
130
ESP-5-070108
toluene
14%
1.6
180
ESP-8-071608
trichloroethene
24%
1.1
130
ESP-7-071008
87
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
SVOCs
Five VOCs were detected in WWTS placed in the ESPs. Table 50 summarizes SVOC frequency of
detection, concentration ranges and location of the maximum concentration.
Table 50: WWTS Data Summary - SVOCs
Analyte
FOD%
minimum
conc.
(if/kg)
maximum
conc.
(MS/kg)
Sample ID of
highest
concentration
benzaldehyde
29%
28
98
ESP-16-092408
bis(2-ethylhexyl)phthalate
19%
120
240
ESP-18-100108
hexachlorobenzene
62%
83
18,000
ESP-17-092908
hexachloroethane
33%
130
960
ESP-6-070808
pyrene
5%
94
94
ESP-19-100208
Inorganics
Eight inorganics were detected in WWTS placed in the ESPs. Table 51 summarizes inorganics detected,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 51: WWTS Data Summary - Inorganics
Analyte
FOD%
minimum
conc.
(mg/kg)
maximum
conc.
(mg/kg)
Sample ID of highest
concentration
arsenic
95%
0.4
19.2
ESP-7-071008
barium
100%
10.3
146
ESP-18-100108-DUP
cadmium
57%
0.17
0.42
ESP-18-100108-DUP
chromium
100%
3.9
61
ESP-16-092408
lead
100%
3.3
56.7
ESP-6-070808
mercury
100%
0.56
185
ESP-6-070808
selenium
38%
0.87
2.2
ESP-18-100108
silver
67%
0.07
0.39
ESP-6-070808
88
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Twenty pesticides were detected in WWTS placed in the ESPs. Table 52 summarizes pesticides detected,
frequency of detection, concentration ranges and location of the maximum concentration.
Table 52: WWTS Data Summary-Pesticides
Analyte
FOD%
minimum
conc.
(Mg/kg)
maximum
conc.
(lig/kg)
Sample ID of
highest
concentration
4,4'-DDD
38%
77
3,700
ESP-6-070808
4,4'-DDE
67%
0.88
330
ESP-7-071008
4,4'-DDT
100%
5.2
3,800
ESP-6-070808
aldrin
38%
1
120
ESP-7-071008
alpha-BHC
33%
0.38
43
ESP-6-070808
alpha-chlordane
33%
2.4
130
ESP-7-071008
beta-BHC
100%
1.7
1,900
ESP-6-070808
beta-chlordane
38%
6.3
250
ESP-7-071008
delta-BHC
33%
0.46
81
ESP-15-081908
dieldrin
76%
1.2
810
ESP-6-070808
endosulfan 1
38%
0.32
64
ESP-15-081908
endosulfan II
38%
5.1
230
ESP-6-070808
endosulfan sulfate
14%
76
2,600
ESP-3-061908
endrin
67%
1.1
880
ESP-6-070808
endrin aldehyde
29%
91
19,000
ESP-5-070108
endrin ketone
19%
4
4,500
ESP-3-061908
gamma-BHC (lindane)
5%
63
63
ESP-15-081908
heptachlor
38%
1
740
ESP-15-081908
heptachlor epoxide
52%
4.3
260
ESP-7-071008
methoxychlor
10%
4
1,600
ESP-15-081908
89
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Dioxins and Furans
Dioxins and furans were detected in all of the samples collected from WWTS placed in the ESPs. Table
53 summarizes dioxin and furans detected, frequency of detection, concentration ranges and location of
the maximum concentration.
Table 53: WWTS Data Summary - Dioxins and Furans
Analyte
FOD%
minimum
conc.
(ng/kg)
maximum
conc.
(ng/kg)
Sample ID of
highest
concentration
1,2,3,4,6,7,8-HpCDD
100%
13.3
1,070
ESP-7-071008
1,2,3,4,6,7,8-HpCDF
100%
31.5
56,700
ESP-6-070808 .
1,2,3,4,7,8,9-HpCDF
100%
2.58
2,420
ESP-6-070808
1,2,3,4,7,8-HxCDD
95%
0.522
24.2
ESP-6-070808
1,2,3,4,7,8-HxCDF
100%
9.84
15,500
ESP-7-071008
1,2,3,6,7,8-HxCDD
100%
0.885
41.3
ESP-7-071008
1,2,3,6,7,8-HxCDF
100%
2.29
2,950
ESP-6-070808
1,2,3,7,8,9-HxCDD
95%
0.558
17.7
ESP-7-071008
1,2,3,7,8,9-HxCDF
76%
0.813
102
ESP-7-071008
1,2,3,7,8-PeCDD
62%
0.439
3.16
ESP-7-071008
1,2,3,7,8-PeCDF
100%
2.66
3,210
ESP-7-071008
2,3,4,6,7,8-HxCDF
100%
3.62
3,350
ESP-6-070808
2,3,4,7,8-PeCDF
100%
1.89
1,580
ESP-6-070808
2,3,7,8-TCDD
100%
0.463
16.7
ESP-2-061708
2,3,7,8-TCDF
100%
18.7
1,670
ESP-7-071008
OCDD
100%
456
8,030
ESP-7-071008
OCDF
100%
53.3
55,400
ESP-6-070808
Total HpCDD
100%
34.8
2,240
ESP-7-071008
Total HpCDF
100%
69.6
67,500
ESP-6-070808
Total HxCDD
100%
6.29
8,635
ESP-18-100108
Total HxCDF
100%
39.3
43,400
ESP-6-070808
Total PeCDD
52%
0.857
33.9
ESP-6-070808
Total PeCDF
100%
31.3
24,900
ESP-18-100108
Total TCDD
95%
1.1
28.3
ESP-7-071008
Total TCDF
100%
68.1
7,690
ESP-7-071008
Toxic Equivalents
100%
17
3,900
ESP-6-070808
90
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.5 Soil
Over 650 soil samples were collected from different areas at the site and background locations. The
results discussion is broken down into the following three sub sections: UPA/UNPA, WBA, and off-site.
5.6.5.1 Upland Area Soil
Over 100 soil samples were collected from the UPA and UNPA. There were analyzed for a variety of
contaminants and summarized below.
VOCs
Ninety-eight soil samples were collected from the UPA and 10 soil samples from the UNPA. Sample
depths ranged from the surface soil to ten ft bgs. Twenty-four VOCs were detected in the UPA, while
only three VOCs were detected in the UNPA. Table 54 summarizes VOCs detected, frequency of
detection, concentration ranges and location of the maximum concentration.
Table 54: Upland Area Soil Data Summary - VOCs
maximum
Analyte
FOD%
minimum
maximum
maximum
location
conc.
conc.
location
depth
(feet)
VOCs via method SW8260. Concentration units are in ng/kg.
1,1-dichloroethane
2%
0.95
2.4
SB-68V
5-10
l,2-dibromo-3-chloropropane
1%
0.89
0.89
SB-77
0-0.5
1,2-dichloroethene (total)
3%
52
52
SB-10
2-2.5
2-butanone
4%
5
600
SB-13
0-0.5
acetone
31%
4.9
28,000
SB-7
1-2
acetophenone
7%
120
220
HC-02
SS
benzene
2%
0.7
3.3
SB-1
2-3.5
bromodichloromethane
2%
6.5
360
SB-13
0-0.5
bromoform
2%
4.5
140
SB-13
0-0.5
bromomethane
1%
3.9
3.9
SB-8
0-0.5
carbon disulfide
27%
0.66
4,800
SB-7
1-2
carbon tetrachloride
3%
3.3
2,400
SB-13
0-0.5
chlorodibromomethane
1%
1.2
1.2
SB-13
2-4
chloroform
8%
1.4
20,000
SB-13
0-0.5
cis-l,2-dichloroethene
3%
0.82
1
SB-70V
1-5
ethyl benzene
3%
1.5
180
SB-13
0-0.5
isopropylbenzene (cumene)
1%
1.9
1.9
SB-310V
0-0.5
methyl isobutyl ketone
23%
4.7
48
SB-13
2-4
methylene chloride
1%
230
230
SB-13
0-0.5
styrene
1%
900
900
SB-13
0-0.5
tetrachloroethene (PCE)
7%
1.1
870
SB-13
0-0.5
91
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
maximum
location
depth
(feet)
toluene
10%
0.81
5
HC-03
SBA
trans-l,2-dichloroethene
2%
2.1
2.1
SB-68V
5-10
trichloroethene (TCE)
6%
0.72
84
SB-13
0-0.5
vinyl chloride
2%
3.4
8.1
SB-10
2-2.5
xylenes (total)
2%
3.3
300
SB-13
0-0.5
SVOCs
One hundred and two soil samples were collected from the UPA and 14 soil samples were collected
from the UNPA and analyzed for SVOCs. Sample depths ranged from the surface soil to ten ft bgs.
Forty-seven SVOCs were detected in the UPA, while only 21 SVOCs were detected in the UNPA. Table
55 summarizes SVOCs detected, frequency of detection, concentration ranges and location of the
maximum concentration.
Table 55: Upland Area Soil Data Summary - SVOCs
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
maximum
location
depth
(feet)
SVOCs via method SW8270. Cor
1,1-biphenyl
icentrati
2%
on units are
0.35
n mg/kg.
0.35
HC-05
SBB
1,2,4-trichlorobenzene
4%
0.03
0.11
SB-1
2-3.5
1,3-dichlorobenzene
3%
0.033
0.039
SB-3
2-5
1,4-dichlorobenzene
1%
0.039
0.039
SB-13
0-0.5
2,4,6-trichlorophenol
1%
2.6
2.6
SB-13
0-0.5
2,4-dichlorophenol
1%
0.12
0.12
SB-13
0-0.5
2,4-dimethylphenol
2%
0.11
0.12
SB-9
0-0.5
2,6-dinitrotoluene
2%
0.14
0.16
SB-8
0-0.5
2-methylnaphthalene
9%
0.021
2.3
SB-14
0-0.5
2-methylphenol
1%
0.075
0.075
SB-14
0-0.5
3,3-dichlorobenzidine
1%
0.18
0.18
SB-70
1-5
3+4-methylphenol
5%
0.062
0.3
HC-06
SBB
4-methylphenol
2%
0.066
0.066
SB-68
5-10
acenaphthene
10%
0.0027
9.3
SB-14
0-0.5
acenaphthylene
3%
0.0025
0.15
SB-14
0-0.5
anthracene
15%
0.0023
16
SB-14
0-0,5
benzaldehyde
4%
0.11
0.28
HB-05
SBB
benzo(a)anthracene
47%
0.0047
37
SB-14
0-0.5
92
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
maximum
location
depth
(feet)
benzo(a)pyrene
28%
0.0045
26
SB-14
0-0.5
benzo(b)fluoranthene
34%
0.02
30
SB-14
0-0.5
benzo(g,h,i)perylene
32%
0.0057
13
SB-14
0-0.5
benzo(k)fluoranthene
36%
0.014
24
SB-14
0-0.5
bis(2-ethylhexyl)phthalate
28%
0.039
15
SB-68
1-5
butyl benzyl phthalate
13%
0.019
2.4
SB-7
0-0.5
caprolactam
6%
0.043
0.064
HC-04
SBA
carbazole
10%
0.0023
7.1
SB-14
0-0.5
chrysene
53%
0.0065
38
SB-14
0-0.5
dibenzo(a,h)anthracene
14%
0.0033
7.8
SB-14
0-0.5
dibenzofuran
7%
0.025
3.7
SB-14
0-0.5
diethyl phthalate
2%
0.023
0.03
SB-4
0-0.5
dimethyl phthlate
19%
0.0035
7.4
SB-13
0-0.5
di-n-butyl phthalate
4%
0.025
1.4
SB-13
0-0.5
di-n-otyl phthalate
4%
0.058
0.27
SB-9
0-0.5
fluoranthene
56%
0.0034
67
SB-14
0-0.5
fluorene
11%
0.0016
7.4
SB-14
0-0.5
hexachlorobenzene
54%
0.006
39
SB-14
0-0.5
hexachlorobutadiene
4%
0.043
0
SB-1
2-3.5
hexachlorocyclopentadiene
1%
0.54
1
SB-13
0-0.5
hexachloroethane
29%
0.011
3.8
SB-1
2-3.5
ideno(l,2,3-cd)pyrene
33%
0.0033
13
SB-14
0-0.5
naphthalene
10%
0.02
2
SB-14
0-0.5
nitrobenzene
1%
0.12
0.12
HC-02
SS
n-nitrosodiphenylamine
1%
0.28
0.28
SB-9
0-0.5
pentachlorophenol
2%
0.67
7.1
SB-13
0-0.5
phenanthrene
46%
0.022
61
SB-14
0-0.5
phenol
2%
0.07
0.11
SB-14
0-0.5
pyrene
57%
0.0028
65
SB-14
0-0.5
Inorganics
One hundred and ten soil samples from the UPA and 16 soil samples from the UNPA were collected and
analyzed for inorganics. Mercury was analyzed in 353 soil samples. Sample depths ranged from the
surface soil to ten fit bgs. Twenty-three inorganics were detected in the UPA, while only 21 inorganicss
were detected in the UNPA. Table 56 summarizes inorganics detected, frequency of detection,
concentration ranges and location of the maximum concentration
93
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 56: Upland Area Soil Data Summary - Inorganics
maximum
Analyte
minimum
maximum
maximum
location
conc.
conc.
location
depth
(feet)
Inorganics via method SW6010/7471. Concentration units are in mg/kg.
aluminum
280
25,200
SB-2
0-0.5
antimony
0.27
40
SB-9
0-0.5
arsenic
0.27
17.1
SB-14
0-0.5
barium
1.6
241
SB-12
0-0.5
beryllium
0.029
1
SB-68
0-0.5
cadmium
0.087
8.3
SB-9
0-0.5
calcium
180
306,000
W-5
0-0.5
chromium
0.99
120
HC-02
SS
cobalt
0.29
22.2
SB-13
0-0.5
copper
0.37
570
HC-01
SS
iron
220
197,000
SB-13
0-0.5
lead
0.79
222
SB-14
0-0.5
magnesium
28
8,140
SB-68
0-0.5
manganese
2
894
SB-13
0-0.5
mercury
0.00822
11,000
HC-05
SBB
nickel
0.52
870
HC-05
SBB
potassium
22
7,260
SB-74
0-0.5
selenium
0.27
1.5
HC-02
SS
silver
0.082
24.4
SB-9
0-0.5
sodium
52.2
5,200
HC-06
SBB
thallium
0.36
4.3
HC-02
SS
vanadium
0.7
93.1
SB-2
0-0.5
zinc
1.9
4,430
SB-14
0-0.5
94
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Ninety-four soil samples from the UPA and 14 soil samples from the UNPA were collected and
analyzed for pesticides. Sample depths ranged from the surface soil to ten feet bgs. Nineteen pesticides
were detected in both the UPA and UNPA. Table 57 summarizes pesticides detected, frequency of
detection, concentration ranges and location of the maximum concentration
Table 57: Upland Area Soil Data Summary - Pesticides
Analyte
minimum
conc.
maximum
conc.
maximum location
maximum
location
depth (feet)
Pesticides via method SW8081. Concentration units are in mg/kg.
4,4'-DDD
0.0002
0.243
SB-1
0-0.5
4,4'-DDE
0.000264
0.154
SB-1
0-0.5
4,4'-DDT
0.00077
1.31
SB-14
0-0.5
aldrin
0.00053
0.525
SB-1
2-3.5
alpha-BHC
0.00019
0.12
UNP-l-SO-1-050609
alpha-chlordane
0.000368
0.286
SB-1
0-0.5
beta-BHC
0.00027
0.092
SB-70
0-0.5
delta-BHC
0.00022
0.014
SB-70
0-0.5
dieldrin
0.00031
0.865
SB-14
0-0.5
endosulfan 1
0.00015
0.0729
SB-14
2-2.5
endosulfan II
0.00014
0.6
SB-4
0-0.5
endosulfan sulfate
0.00021
0.162
SB-14
0-0.5
endrin
0.00024
0.264
SB-4
0-0.5
endrin aldehyde
0.001
0.6
SB-70
1-5
endrin ketone
0.53
0.53
HC-02
SBA
gamma-BHC (lindane)
0.00016
0.15
SB-70
0-0.5
gamma-chlordane
0.00267
0.286
SB-13
0-0.5
heptachlor
0.000448
0.721
SB-1
2-3.5
heptachlor epoxide
0.0002
0.049
SB-9
1-5
methoxychlor
0.00026
0.48
HC-06
SBB
95
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
PCBs
Two hundred and thirty soil samples from the UPA and 14 soil samples from the UNPA were collected
and analyzed. Sample depths ranged from the surface soil to 10 ft bgs. Table 58 summarizes PCBs
detected, frequency of detection, concentration ranges and location of the maximum concentration
Table 58: Upland Area Soil Data Summary - PCBs
Analyte
minimum
conc.
maximum
conc.
maximum
location
maximum
location
depth
(feet)
Aroclors via method SW8082. C
Aroclor 1254
oncent ration
0.0074
units are in m{
5.1
[/kg-
SB-69
1-5
Aroclor 1268
0.0036
2,500
SB-63
1-3
PCB Congeners via method E16<
PCB-77
>8. Concentn
3.6
ition units are
2,970
n ng/kg.
SB-70
1-5
PCB-81
4.93
810
SB-70
1-5
PCB-105
10.9
23,100
SB-69
0.5-1
PCB-106/118
27.9
129,000
SB-69
0.5-1
PCB-114
3.2
1,030
SB-69
0.5-1
PCB-123
6.75
632
SB-70
1-5
PCB-126
7.18
697
SB-70
1-5
PCB-156
5.56
16,200
SB-69
0.5-1
PCB-157
4.56
2,750
SB-69
0.5-1
PCB-167
4.18
7,310
SB-69
0.5-1
PCB-169
3.48
991
SB-70
1-5
PCB-189
8.29
8,800
SB-70
1-5
Dioxins and Furans
Twenty-five soil samples from the UPA and five soil samples from the UNPA were collected and
analyzed for dioxins and furans. Sample depths ranged from the surface soil to ten feet bgs.
96
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Record of Decision Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
Table 59 summarizes dioxin and furans detected, frequency of detection, concentration ranges and
location of the maximum concentration.
97
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 59: Upland Area Soil Data Summary - Dioxins/Furans
Analyte
minimum
conc.
maximum
conc.
maximum
location
maximum
location
depth (feet)
Dioxins/Furans via method E1613. Concentration uni
1,2,3,4,6,7,8-HpCDD
ts are in ng/li
0.997
«¦
518
SB-75
1-5
1,2,3,4,6,7,8-HpCDF
0.328
5,200
SB-69
0-0.5
1,2,3,4,7,8,9-HpCDF
0.155
352
SB-70
0-0.5
1,2,3,4,7,8-HxCDD
0.257
11.3
SB-68
5-10
1,2,3,4,7,8-HxCDF
0.485
1,130
SB-70
0-0.5
1,2,3,6,7,8-HxCDD
0.283
8.32
SB-75
1-5
1,2,3,6,7,8-HxCDF
0.197
205
SB-69
0-0.5
1,2,3,7,8,9-HxCDD
0.303
7.92
SB-68
5-10
1,2,3,7,8,9-HxCDF
0.334
30.5
SB-69
0-0.5
1,2,3,7,8-PeCDD
0.252
2.23
SB-68
5-10
1,2,3,7,8-PeCDF
0.499
150
SB-70
0-0.5
2,3,4,6,7,8-HxCDF
0.171
301
SB-70
1-5
2,3,4,7,8-PeCDF
0.258
132
SB-70
1-5
2,3,7,8-TCDD
0.252
0.728
SB-69
0-0.5
2,3,7,8-TCDF
0.827
60
SB-70
0-0.5
OCDD
68
7,450
SB-75
1-5
OCDF
0.371
4,520
SB-69
0-0.5
HpCDD
4.49
2,000
SB-75
1-5
HpCDF
0.328
7,520
SB-69
0-0.5
HxCDD
1.07
260
SB-68
5-10
HxCDF
0.11
4,100
SB-70
1-5
PeCDD
0.181
25.7
SB-68
5-10
PeCDF
0.258
1,200
SB-70
1-5
TCDD
0.199
8.37
SB-70
1-5
TCDF
0.348
399
SB-70
1-5
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
1.52
668
SB-70
1-5
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
0.48
265
SB-69
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) -
Mammal
0.92
334
SB-70
1-5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
0.53
366
SB-70
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
0.46
264
SB-69
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
0.4
250
SB-69
0-0.5
Total 2,3,7,8-TCDD TEQ (PCB) - Bird
0.69
303
SB-70
1-5
Total 2,3,7,8-TCDD TEQ (PCB) - Fish
0.02
5
SB-70
1-5
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
0.36
102
SB-70
1-5
98
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.5.2 WBA Soil
The WBA consists of approximately nine acres of land with three drainage pathways that slope to the
Cape Fear River. A broad range of constituents were detected in the WBA. Sample depths ranged from
the surface soil to one foot bgs. Table 60 lists the range for percent solids and total organic carbon for the
WBA soils.
Table 60: Bottomland Area Soil Data Summary - Percent Solids and TOC
Analyte
minimum
conc.
maximum
conc.
maximum
location
sample depth
(feet)
E160.3
Total Solids (%)
55.98%
93.97%
WB-2
SM2540G
Percent Solids
74.40%
91.80%
WB-2
SW9060 mg/kg
Total Organic Carbon
19,000
42,000
SB-98
0-0.5
VOCs
Thirty-one soil samples were collected from the WBA and were analyzed for VOCs. Six VOCs were
detected. Table 61 includes the concentration ranges for detected VOCs, the sample ID and depth for the
maximum concentration.
Table 61: Bottomland Area Soil Data Summary - VOCs
Analyte
minimum
conc.
maximum
conc.
maximum
location
sample depth
(feet)
VOCs via method SW8260. Co
2-butanone
ncentration
9.1
jnits are in \ig/
9.1
kg.
SB-79
0-0.5
carbon disulfide
1.1
1.1
SB-98
0-0.5
Chloroform
0.71
2
SB-95
0.5-1
isopropylbenzene (cumene)
1.5
24
SB-96
0-0.5
Toluene
1.1
2.3
SB-79
0-0.5
Trichlorofluoromethane
1.8
1.8
SB-96
0.5-1
99
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Record of Decision
LCP-HoItrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
SVOCs
Thirty-five soil samples were collected from the WBA and analyzed for SVOCs. Twenty-six SVOCs
were detected. Table 62 includes the concentration ranges for detected SVOCs, the sample ID and depth
for the maximum concentration.
Table 62: Bottomland Area Soil Data Summary - SVOCs
Analyte
minimum
conc.
maximum
conc.
maximum
location
sample
depth (feet)
SVOCs via method SW8270. C
3,3-dichlorobenzidine
oncentration
0.12
units are in mj
0.27
S/kg-
SB-89
0.5-1
acenaphthene
0.0012
0.02
SB-99
0-0.5
acenaphthylene
0.0016
0.0016
TERA-3
0-1
anthracene
0.003
0.03
SB-89 & SB-99
0-1
benzo(a)anthracene
0.0068
0.46
SB-99
0-0.5
benzo(a)pyrene
0.0022
0.39
SB-99
0-0.5
benzo(b)fluoranthene
0.015
0.6
SB-99
0-0.5
benzo(g,h,i)perylene
0.0061
0.21
SB-99
0-0.5
benzo(k)fluoranthene
0.04
0.56
SB-99
0-0.5
bis(2-ethylhexyl)phthalate
0.11
0.24
SB-89
0.5-1
butyl benzyl phthalate
0.051
0.051
SB-90
0-0.5
caprolactam
0.0071
0.013
TERA-5
0-1
carbazole
0.0017
0.16
SB-99
0-0.5
chrysene
0.0096
0.91
SB-99
0-0.5
dibenzo(a,h)anthracene
0.11
0.11
SB-99
0-0.5
dibenzofuran
0.033
0.033
SB-99
0-0.5
dimethyl phthlate
0.038
0.042
TERA-5
0-1
di-n-butyl phthalate
0.054
0.054
SB-94
0-0.5
di-n-otyl phthalate
0.042
0.042
TERA-3
0-1
fluoranthene
0.0068
1.8
SB-99
0-0.5
fluorene
0.0018
0.025
SB-99
0-0.5
hexachlorobenzene
0.035
0.28
SB-91
0-0.5
hexachloroethane
0.026
0.12
SB-91
0-0.5
ideno(l,2,3-cd)pyrene
0.0016
0.21
SB-99
0-0.5
phenanthrene
0.16
1.2
SB-99
0-0.5
pyrene
0.0047
1.6
SB-99
0-0.5
100
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Inorganics
Forty-two soil samples were collected from the WBA and analyzed for inorganics and 68 soil samples
were collected and analyzed for mercury. Many inorganics naturally occur in soil. Table 63 includes the
concentration ranges for detected inorganics, the sample ID and depth for the maximum concentration.
Table 63: Bottomland Area Soil Data Summary - Inorganics
Analyte
minimum
conc.
(mg/kg)
maximum
conc.
(mg/kg)
maximum
location
sample depth
(feet)
Inorganics via method SW6010/7
aluminum
471.
1,200
25,900
SB-94
0.5-1
arsenic
0.3
6.7
SB-94
0-0.5
barium
7.9
166
SB-80 & SB-94
0-0.5
beryllium
0.17
1.3
SB-94 & SB-97
0-0.5
cadmium
0.06
2.7
SB-94
0-0.5
calcium
362
25,400
WB-3
0-1
chromium
2.2
52.1
SB-93
0-0.5
cobalt
0.38
18.5
SB-94
0.5-1
copper
1.1
65.8
SB-94
0-0.5
iron
1,590
30,600
SB-94
0.5-1
lead
2.1
122
SB-94
0-0.5
magnesium
148
2,690
SB-98
0-0.5
manganese
16.5
1,020
SB-93
0-0.5
nickel
1.5
59.6
SB-94
0-0.5
potassium
96.5
2,100
SB-91
0-0.5
selenium
0.65
1.7
SB-97
0-0.5
silver
0.21
3.9
SB-94
0-0.5
sodium
44.1
5,600
HC-14
SS
thallium
0.33
2
SB-97
0-0.5
vanadium
4.4
81.3
SB-93
0-0.5
zinc
3.7
781
SB-94
0-0.5
Methylmercury via method E1630.
methylmercury | 0.00064 | 0.0222 | WB-5 | 0-1
Mercury fractions via method Ell
mercury
>31.
0.136
32.3
TERA-5
0-1
mercury fraction 1 Bloom ES&T
0.00768
1.6
TERA-5
0-1
mercury fraction 2 Bloom ES&T
0.00255
0.0239
TERA-5
0-1
mercury fraction 5 Bloom ES&T
0.00382
19.2
TERA-5
0-1
Mercury via method 7471.
mercury
0.02
92
SB-94
0-0.5
101
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Record of Decision Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
Table 64 lists the sample IDs and concentrations that exceeded the mercury PRG.
Table 64: Wooded Bottomland Surface Soil Sample Results that Exceed an Inorganic PRG
Location ID
Mercury
(mg/kg)
Preliminary Remediation Goal (PRG):
3
HC-13
8.4
HC-14
4.6
SB-79
4.7
SB-80
86.3
SB-89
34.8
SB-90
21.7
SB-91
72.8
SB-94
92
SB-97
14.4
SB-98
15.1
SB-99
21.4
Site #1 Surface
3.5
Site #2 Surface
16.2
TERA-5(E1631)
32.3 J
TERA-5 (SW7471)
19.8
WB-3 (SW7471)
16.8
WB-4 (E1631)
10.8
Notes:
Only samples that had a concentration that exceeded the PRG
are included in this table.
J = estimated concentration
Figure 22 illustrates the distribution of the mercury in WBA soil. The northeastern portion of this area
was designated as wetlands and is influenced primarily by the central drainage pathway. As evidenced
by the pattern of occurrence, the mercury likely originated from the Fill and Retort Areas runoff and was
transported in surface water and sediment from the central drainage pathway to the wetland areas.
102
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Figure 22: Concentrations exceeding PRGs in Bottomlands
|t6Ntlki"l*AfK5N4 6f ME*Cu*v *n6 1.4.U - Tc66 ttfl
EXCEEDING RGOt IN BOTTOMLANDS SURFACE SOIL (0-0S)
LCP HOLTRACHEM SITE
RIEGEUVOOD NOa.T- CARQUNA
DATE JANUARY 20*3
AfOfKi^K.
103
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Pesticides
Thirty-five soil samples were collected from the WBA and analyzed for pesticides. Seventeen pesticides
were detected. Table 65 includes the concentration ranges for detected pesticides, the sample ID and
depth for the maximum concentration.
Table 65: Wooded Bottomland Soil Data Summary - Pesticides
Analyte
minimum
conc.
(mg/kg)
maximum
conc.
(mg/kg)
maximum
location
sample depth
(feet)
Pesticides via method SW808
4,4'-DDD
1
0.00026
0.17
TERA-5
0-1
4,4'-DDE
0.00032
1.4
SB-89
0.5-1
4,4'-DDT
0.00075
2.3
SB-89
0.5-1
aldrin
0.00075
0.062
SB-89
0.5-1
alpha-BHC
0.00098
0.028
SB-89
0.5-1
beta-BHC
0.00041
0.16
SB-90
0.5-1
delta-BHC
0.00021
0.016
SB-79
0-0.5
dieldrin
0.00034
0.16
SB-89
0.5-1
endosulfan 1
0.000098
0.19
SB-89
0.5-1
endosulfan II
0.00014
0.51
SB-89
0.5-1
endosulfan sulfate
0.00021
0.021
SB-79
0-0.5
endrin
0.00053
0.76
SB-89
0.5-1
endrin aldehyde
0.0033
1.4
SB-89
0.5-1
gamma-BHC (lindane)
0.00018
0.021
SB-79
0-0.5
heptachlor
0.0092
0.14
SB-89 & SB-94
0-1
heptachlor epoxide
0.00028
0.24
SB-89
0.5-1
methoxychlor
0.0021
0.082
SB-89
0.5-1
104
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Aroclors
Ninety-seven soil samples were collected from the WBA and analyzed for Aroclor 1268. Sixty-four soil
samples were collected from the WBA and analyzed for Aroclor 1254. Table 66 includes the
concentration ranges for detected Aroclors, the sample ID and depth for the maximum concentration.
Table 66: Wooded Bottomland Soil Data Summary - PCBs
Analyte
minimum
conc.
(mg/kg)
maximum
conc.
(mg/kg)
maximum
location
sample depth
(feet)
PCBs via method SW8082
Aroclor 1254
0.0045
67
SB-89
0.5-1
Aroclor 1268
0.0071
1,200
SB-89
0.5-1
PCBs via method SW8280
PCB 1268
0.027
3,800
SITE#1
0-0.5
Table 67 lists the samples and concentrations that exceeded the PRGs.
Table 67: Wooded Bottomland Surface Soil Sample Results that Exceed a PCB PRO
Sample ID
Sample
Depth
(feet)
Aroclor
1254
(mg/kg)
Aroclor
1268
(mg/kg)
Preliminary Remediation Goal (PRG):
21
21
SB-80
0-0.5
<9.8
190 B
SB-89
0-0.5
0.31 J
38
SB-89
0.5-1
67
1200
SB-90
0-0.5
1.5 J
130
SB-90
0.5-1
<2.4
130
SB-91
0-0.5
2.2 J
400
SB-94
0-0.5
<2.7
460
SB-94
0.5-1
<0.48
24
SB-97
0-0.5
1.1 J
150
SB-98
0-0.5
<0.58
23
SB-99
0-0.5
0.25 J
31
SB-177
0-1
NA
32.2
Site #1 Surface
0-0.5
<36
3800
Site #2 Surface
0-0.5
<37
1500
Site #2 B2
0-0.8
< 1.7
46
TERA-5
0-0.5
< 0.091
21
Notes:
Only samples that had a concentration that exceeded at least one PRG are included
in this table.
105
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Record of Decision
LCP-Holtrachem Superfund Site
Sample ID
Sample
Depth
(feet)
Preliminary F
Aroclor
1254
(mg/kg)
Aroclor
1268
(mg/kg)
B = blank contamination. The anaiyte was found in an associated blank as well as in
the sample
J = estimated concentration
NA = not analyzed
< = less than the reporting limit. The reporting limit is included.
< = less than the reporting limit. The reporting limit is included and exceeds the
PRG.
Bold value exceeds PRG
Summary of Remedial Alternative Selection
September 2017
Figure 23 illustrates the distribution of the PCBs in soil. The northeastern portion of this area was
designated as wetlands and is influenced primarily by the central drainage pathway. Aroclor 1268 likely
originated from historical Fill Area runoff and was transported in surface water and sediment from the
central drainage pathway to the wetland areas.
Figure 23: Concentrations of Aroclor 1268 Exceeding PRG in Bottomlands
CONCENTRATIONS OF AROCLOR 1268 EXCEEDING RGO IN BOTTOMLANDS
iface son. (0-r)
LCP - HOLTRACHEM SITE
RIEGELWOQD, NORTH CAROUNA
amec*
DRAWN: WBM JOfi: 6550 12-0036
APPROVAL 3Wj PATE: JANUARY 2013
SCALE: AS SHOWNjfiQ: 4-140 '
106
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Dioxins/Furans and PCBs
Thirty-two soil samples were collected from the WBA and analyzed for dioxins/furans and dioxin/furan-
like PCB congeners. Table 68 and Table 69 include the concentration ranges for detected PCB congeners
and dioxins/furans respectively.
Table 68: Bottomland Area Soil Data Summary - PCB congeners
Analyte
minimum
conc.
(ng/kg)
maximum
conc.
(ng/kg)
maximum
location
sample depth
(feet)
PCB congeners via method E1668.
PCB-77
2.51
11,700
SB-94
0-0.5
PCB-81
2.84
1,870
SB-91
0-0.5
PCB-105
21.8
50,000
SB-91
0-0.5
PCB-106/118
39.3
191,000
SB-91
0-0.5
PCB-114
2.04
2,490
SB-91
0-0.5
PCB-123
2.65
2,010
SB-91
0-0.5
PCB-126
1.66
1,870
SB-91
0-0.5
PCB-156
15.2
22,000
SB-91
0-0.5
PCB-157
3.13
5,760
SB-91
0-0.5
PCB-167
13.9
18,800
SB-91
0-0.5
PCB-169
2.24
3,260
SB-94
0-0.5
PCB-189
18.2
24,700
SB-91 & SB-94
0-0.5
107
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Table 69: Bottomland Area Soil Data Summary - Dioxins/Furans
Analyte
minimum
conc.
(ng/kg)
maximum
conc.
(ng/kg)
maximum
location
sample
- depth
(feet)
Dioxins/furans via method E1613.
1,2,3,4,6,7,8-HpCDD
2.44
2,990
SB-91
0-0.5
1,2,3,4,6,7,8-HpCDF
4.3
20,800
SB-94
0-0.5
1,2,3,4,7,8,9-HpCDF
0.84
988
SB-94
0-0.5
1,2,3,4,7,8-HxCDD
0.368
29.2
SB-90
0.5-1
1,2,3,4,7,8-HxCDF
2.08
5,550
SB-94
0-0.5
1,2,3,6,7,8-HxCDD
0.608
56.2
SB-97
0-0.5
1,2,3,6,7,8-HxCDF
0.499
1,090
SB-94
0-0.5
1,2,3,7,8,9-HxCDD
0.475
29.7
SB-94
0-0.5
1,2,3,7,8,9-HxCDF
0.412
217
SB-94
0-0.5
1,2,3,7,8-PeCDD
0.243
8.89
SB-94
0-0.5
1,2,3,7,8-PeCDF
0.311
531
SB-94
0-0.5
2,3,4,6,7,8-HxCDF
0.552
1,600
SB-94
0-0.5
2,3,4,7,8-PeCDF
0.396
679
SB-94
0-0.5
2,3,7,8-TCDD
0.163
7.14
SB-94
0-0.5
2,3,7,8-TCDF
0.514
293
SB-94
0-0.5
HpCDD
6.49
6,210
SB-91
0-0.5
HpCDF
6.15
31,600
SB-94
0-0.5
HxCDD
0.747
1,080
SB-97
0-0.5
HxCDF
6.33
22,400
SB-94
0-0.5
OCDD
53.1
40,700
SB-91
0-0.5
OCDF
1.53
21,700
SB-94
0-0.5
PeCDD
0.346
342
SB-97
0-0.5
PeCDF
1.77
9,390
SB-94
0-0.5
TCDD
0.274
77
SB-94
0-0.5
TCDF
0.846
4,630
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Bird
2.3
3,041
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan & PCB) - Fish
1.3
1,495
SB-94
0-0.5
Total 2,3,7,i8-TCDD TEQ (dioxin/furan & PCB) - Mammal
1.48
1,660
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Bird
1.52
2,118
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Fish
1.27
1,484
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (dioxin/furan) - Mammal
1.15
1,384
SB-94
0-0.5
Total 2,3,7,8-TCDD TEQ (PCB) - Bird
0.81
967
SB-91
0-0.5
Total 2,3,7,8-TCDD TEQ (PCB) - Fish
0.01
13
SB-91
0-0.5
Total 2,3,7,8-TCDD TEQ (PCB) - Mammal
0.32
282
SB-91
0-0.5
Table 70 lists sample locations with surface soil results that exceeded 2,3,7,8-TCDD TEQ PRGs.
108
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 70: Wooded Bottomland Area Soil Sample locations that Exceed a Dioxin PRG
Avian Ecological
Human Health
Location ID
Total 2,3,7,8-
TCDD TEQ
(dioxin/furan)
(mg/kg)
Total 2,3,7,8-
TCDD TEQ (PCB)
(mg/kg)
Total 2,3,7,8-
TCDD TEQ
(dioxin/furan +
PCB) (mg/kg)
Preliminary
Remediation Goal (PRG):
0.0000854
0.000196
0.000936
SB-89
0.000285
0.000109
0.00024
SB-90
0.000849
0.000262
0.000651
SB-91
0.00167
0.000967
0.00136
SB-94
0.00212
0.000923
0.00166
SB-97
0.00104
0.000264
0.000743
SB-98
0.000112
0.0000321
0.0000613
SB-99
0.000275
0.000128
0.000189
Notes:
Only samples that had a concentration that exceeded the PRG are included in this table.
Bold value exceeds PRG
109
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.5.3 Off-site Soil
Eight soil samples were collected from background locations. The background soil data indicated that a
broad range of constituents were present in surface and subsurface soils to a depth of 5 feet. Table 71
through Table 74 include summary statistics of the detected constituents in background soils. Figure 24
illustrates the locations of the background samples.
Table 71: Background Soil Data Summary - Percent Solids, TOC, VOCs and SVOCs
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
sample depth (feet)
E160.3
Total Solids (%) 100% 91.46% 91.46% SOREF-050709 |
SM2540G
Percent Solids 100% 92% 92% SOREF-050709
SW9060 mg/kg
Total Organic Carbon 100% 1,700 15,000 SB-104 0-0.5
VOCs via method SW8260. Co
2-butanone
ncentral
19%
ion units are
0.0055
in mg/kg.
0.0066
SB-105
0-0.5
acetone
38%
0.013
0.14
SB-105
0-0.5
toluene
19%
0.00083
0.00094
SB-104
0-0.5
trichlorofluoromethane
60%
0.0016
0.0023
SB-104
0-0.5
SVOCs via method SW8270. C
benzo(a)anthracene
oncentrc
7%
ition units ar
0.0029
e in mg/kg.
0.0029
SOREF-050709
benzo(a)pyrene
7%
0.0024
0.0024
SOREF-050709
benzo(b)fluoranthene
7%
0.0066
0.0066
SOREF-050709
benzo(g,h,i)perylene
7%
0.0061
0.0061
SOREF-050709
bis(2-ethylhexyl)phthalate
7%
0.1
0.1
SB-28
2-5
chrysene
7%
0.0049
0.0049
SOREF-050709
dibenzo(a,h)anthracene
7%
0.0053
0.0053
SOREF-050709
fluoranthene
7%
0.0019
0.0019
SOREF-050709
ideno(l,2,3-cd)pyrene
7%
0.0063
0.0063
SOREF-050709
110
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 72: Background Soil Data Summary - Inorganics
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
sample depth (feet)
Inorganics via method SW601
aluminum
0/7471.
100%
Concentratio
343
n units are in r
24,000
ng/kg.
SB-28
2-5
antimony
6%
0.49
0.49
SB-28
2-5
arsenic
75%
0.26
3.5
SB-28
2-5
barium
100%
3.6
17.5
SB-28
2-5
beryllium
44%
0.041
0.25
SB-28
2-5
cadmium
19%
0.099
0.21
SB-105
1-5
calcium
100%
18.2
448
SB-26
0-0.5
chromium
94%
1.1
36
HC-23-SBB
cobalt
31%
0.39
1.2
SB-28
2-5
copper
44%
0.54
3.2
SB-28
2-5
iron
100%
.384
34,000
HC-23-SBB
lead
100%
2.4
10
HC-23-SBB
magnesium
100%
22.5
415
SB-28
2-5
manganese
100%
3.3
17.1
SB-26
0-0.5
mercury
56%
0.016
0.044
SB-104
0-0.5
nickel
94%
0.44
4.2
SB-28
2-5
potassium
50%
25.9
240
HC-23-SBB
selenium
13%
0.35
1.8
HC-23-SBB
sodium
19%
320
390
HC-23-SBB
thallium
25%
0.33
2.8
HC-23-SBB
vanadium
100%
3.7
49.1
SB-28
2-5
zinc
88%
1
8.8
HC-23-SBB
E1630 (mg/kg)
methylmercury 1 100% 0.00013 0.00013 SOREF-050709
E1631 (mg/kg)
mercury 100% 0.0268 0.0268 SOREF-050709
111
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 73: Background Soil Data Summary - Pesticides and PCBs
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
sample depth (feet)
Pesticides via method SW808
4,4'-DDD
1. Conce
19%
ntration unit
0.00027
s are in mg/kg.
0.00042
SB-104
0-0.5
4,4'-DDE
25%
0.00053
0.00137
SB-26
0-0.5
4,4'-DDT
13%
0.00069
0.00072
SB-104
0-0.5
alpha-chlordane
10%
0.000381
0.000381
SB-27
0-0.5
endosulfan 1
19%
0.00021
0.000782
SB-27
0-0.5
endosulfan II
13%
0.00014
0.00015
SB-104
0-0.5
endosulfan sulfate
25%
0.00029
0.0014
SB-104
0-0.5
endrin
13%
0.00024
0.00071
SOREF-050709
gamma-BHC (lindane)
10%
0.00028
0.00028
SB-104
0-0.5
gamma-chlordane
11%
0.000967
0.000967
SB-27
0-0.5
heptachlor epoxide
20%
0.00018
0.00033
SB-104
0-0.5
methoxychlor
30%
0.00042
0.00095
SB-104
0-0.5
PCBs via method SW8082. Concentration units are in mg/kg.
Aroclor 1268 54% 0.0078 0.245 SB-26 0-0.5
PCB congeners via method El
PCB-105
568. Cor
50%
centration ui
8.79
lits are in ng/k
45.2
S-
SB-105
0-0.5
PCB-106/118
50%
22
117
SB-105
0-0.5
PCB-156
33%
15.5
19.2
SB-105
0-0.5
PCB-167
33%
9.79
9.8
SB-104
0-0.5
PCB-189
33%
5.35
7.67
SB-104
0-0.5
112
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Record of Decision
LCP-Holtrachem Superfiind Site
Summary of Remedial Alternative Selection
September 2017
Table 74: Background Soil Data Summary - Dioxins/Furans
Analyte
FOD%
minimum
conc.
maximum
conc.
maximum
location
sample depth (feet)
Dioxins/furans via method El
1,2,3,4,6,7,8-HpCDD
613.Con
100%
centration ui
8.49
lits are in ng/k
58.9
g-
SB-104
1-5
1,2,3,4,6,7,8-HpCDF
67%
0.504
2.52
SB-104
0-0.5
1,2,3,4,7,8-HxCDF
67%
0.264
0.863
SB-104
0-0.5
1,2,3,6,7,8-HxCDD
17%
1.93
1.93
SB-105
0-0.5
1,2,3,6,7,8-HxCDF
33%
0.309
0.323
SB-105
0-0.5
1,2,3,7,8,9-HxCDD
17%
0.811
0.811
SB-104
0-0.5
1,2,3,7,8-PeCDD
50%
0.931
8.24
SB-105
0-0.5
2,3,4,6,7,8-HxCDF
50%
0.51
0.804
SB-105
0-0.5
2,3,7,8-TCDD
50%
3.12
5.38
SB-104
0-0.5
2,3,7,8-TCDF
33%
0.828
1.19
SB-105
0-0.5
HpCDD
100%
23.2
128
SB-104
1-5
HpCDF
67%
0.504
3.53
SB-104
0-0.5
HxCDD
100%
1.7
234
SB-105
0-0.5
HxCDF
80%
0.264
13.5
SB-105
0-0.5
OCDD
100%
288
8,890
SB-104
1-5
OCDF
33%
1.57
1.6
SB-104
0-0.5
PeCDD
67%
0.917
92
SB-105
0-0.5
PeCDF
50%
6.53
18.6
SB-105
0-0.5
TCDD
50%
4.69
6.6
SB-104
0-0.5
TCDF
50%
6.28
10.4
SB-105
0-0.5
113
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Figure 24: Background Samples Location Map
InUmmh: Mm Ii6» iiii '.j imk
«PIHO»M mra^l
HM, lailmm hturn i;
114
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
5.6.6 Groundwater
Groundwater monitoring at the site began in the early 1990s to comply with RCRA requirements. After
RCRA transferred the site to the CERCLA program, contractors conducted additional groundwater
monitoring to determine the nature and extent of groundwater contamination.
5.6.6.1 RCRA Groundwater Monitoring Data
Before 2000, RCRA regulated site activities. The RCRA groundwater monitoring included sampling 15
wells as part of post-closure monitoring in accordance with the hazardous waste permit. This included
annual and quarterly groundwater sampling from about 1992 through 2003.
The monitoring wells were located in the upland non-process and bottomland areas. The wells included
BG (background); POC-1, POC-1R, POC-2, POC-2R and POC-3; NUS-4R, 4A, 5A, 9A, 10A, 10AR,
10B, 10BR, 11 A, 1 IB, 13A, and 14A. Figure 25 shows well locations.
Figure 25: Monitoring Well Locations
DRAWN
MONITORING WELL LOCATIONS
LCP - HOLTRACKEM SHE
RIEGELWOOO. NORTH CAROLINA
APPROVAi BWJ DATE: iANiUARV ?Q1 T,
SCA1T SHOWN p-jG 4-15
Annual Sampling
Under RCRA, the facility performed annual monitoring for the three POC wells. Table 75 through Table
77 summarize the results of RCRA annual sampling events.
115
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 75: Detected Analytes in POC-1/POC-1R during January 1993 - December 2000
Analyte
Standards
POC-1**
POC-1R
2L
MCL
Jan-93
Dec-93
Dec-94
Dec-95
Dec-96
Dec-98
Jan-00 | Dec-00
VOCs (ug/L)
1,1-dichloroethane
7
7
ND
ND
ND
ND
ND
ND
1
ND
trans- 1,2-dichloroethene
100
100
ND
IMD
ND
ND
ND
ND
1
ND
tetrachloroethene (PCE)
0.7
5
ND
ND
ND
ND
ND
ND
2
ND
trichloroethene (TCE)
2.8
5
ND
ND
ND
ND
ND
ND
19
5
vinyl chloride
0.015
2
ND
ND
ND
ND
ND
ND
1
ND
Inorganics (mg/L)
arsenic
0.05
0.01
ND
0.014
ND
ND
ND
ND
ND
ND
barium
2
2
0.084
ND
0.056
0.035
0.059
ND
0.172
0.2
chromium
0.05
0.1
ND
0.052
ND
ND
0.005
ND
ND
ND
lead
0.015
0.015
ND
ND
0.011
ND
0.007
*
ND
ND
mercury
0.00105
0.002
0.0042
0.043
0.002
ND
0.0006
*
0.0019
ND
zinc
1.05
5
0.22
0.12
0.07
0.028
0.052
ND
ND
ND
Notes:
* no data readily available
"Well POC-1 was destroyed in
September 1999 and replaced in December 1999. The new POC well was named POC-1R.
2L = Title 15A North Carolina Administrative Code Subchapter 2LGroundwater Standards (I5A NCAC 2L Standard)
MCL = Safe Drinking Water Act's Maximum Contaminant Level
ND = not detected
mg/L = milligrams per liter
Ug/L = micrograms per liter
concentration exceeds 2Lvalue but is less than the MCL
concentration exceeds MCL
Table 76: Detected Analytes in POC-2/POC-2R during January 1993 - December 2003
Analyte
Standards
POC-2**
POC-2R
2L
MCL
Jan-93
Dec-93
Dec-94
Dec-95
Dec-96
Dec-98
Jan-00
Dec-00
Dec-01
Dec-Q2
Dec-03
Inorganics (n
iR/U
arsenic
0.05
0.01
ND
ND
ND
ND
ND
ND
ND
ND
0.0114
ND
ND
barium
2
2
0.067
ND
0.041
0.03
0.022
ND
0.398
0.35
0.327
0.234
ND
mercury
0.00105
0.002
ND
ND
ND
ND
0.0002
*
0.0012
ND
ND
ND
ND
selenium
0.05
0.05
ND
ND
ND
ND
0.007
*
ND
ND
ND
ND
ND
vanadium
NS
NS
ND
0.063
ND
ND
ND
ND
ND
ND
ND
ND
ND
zinc
1.05
5
0.1
0.058
0.062
0.029
0.013
ND
ND
0.0224
ND
0.0306
ND
Notes:
Only analytes with at least one detection are included in this table. No VOCs, SVOCs, pesticides, herbicides or dioxins were detected.
* no data readijy avaHable_ __ _ _
**Well POC-2 was destroyed in September 1999 and replaced in January 2000. The new well was named POC-2R.
2L = Title ISA North Carolina Administrative Code Subchapter 2L Groundwater Standards (15A NCAC 2L Standard) _
MCL = Safe Drinking Water Act's Maximum Contaminant Level
ND = nmdetected _
NS = no standard has been established
mg/L = milligrams per [iter
concentration exceeds 2L value but is less than the MCL
concentration exceeds MCL
116
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 77: Detected Analytes in POC-3 during January 1993 - December 2003
Analyte
Standards
POC-3
2L
MCL
Jan-93
Dec-93
Dec-94
Dec-95
Dec-96
Dec-98
Jan-00
Dec-00| Dec-0l| Dec-02| Dec-03
VOCs (Mg/L)
carbon disulfide
700| NS
ND
ND
ND
ND
ND
ND| 1
1
17
ND
ND
Inorganics (mg/L)
barium
2
2
0.17
ND
0.085
0.072
0.081
ND
ND
ND
ND
ND
ND
beryllium
NS
0.004
ND
ND
ND
ND
0.002
ND
ND
ND
ND
ND
ND
chromium
0.05
0.1
0.14
0.09
ND
ND
0.005
ND
ND
ND
ND
ND
ND
lead
0.015
0.015
ND
ND
0.01
ND
ND
+
ND
ND
ND
ND
ND
mercury
0.00105
0.002
ND
ND
ND
ND
ND
*
0.0026
ND
ND
ND
ND
zinc
1.05
5
0.24
0.13
0.061
0.041
0.055
ND
ND
ND
ND
0.0299
ND
Notes:
Only analytes with at least one detection are included in this table. No SVOCs, pesticides, herbicides or dioxins were detected.
* no data readily available
2L = Title 15A North Carolina Administrative Code Subchapter 2L Groundwater Standards (I5A NCAC 2L Standard)
MCL = Safe Drinking Water Act's Maximum Contaminant Level
ND = not detected
NS = no standard has been established
mg/L = milligrams per liter
Hg/L = micrograms per liter
concentration exceeds MCL
Analytical results did not detect SVOCs, dioxins, pesticides, or herbicides in any of the well samples.
PCBs were not required to be analyzed under RCRA. Analytical results did not detect VOCs at
concentrations above drinking water standards in wells POC-1, POC-2, POC-2R and POC-3.
In 1999, the damaged POC-1 well was replaced with POC-1R. In January 2000, three VOCs were
detected in well POC-1 R above drinking water standards. These included PCE, TCE and vinyl chloride.
In December 2000, the concentrations of these three VOCs decreased to non-detect for PCE and vinyl
chloride, and from 19 to 5 |ig/L for TCE.
Analytical results indicated concentrations of arsenic, chromium and mercury were in excess of drinking
water standards sporadically in POC wells.
Quarterly sampling
Under RCRA. 15 wells were sampled quarterly from August 1992 through December 2003. Analysis
was limited to mercury and select inorganic indicator parameters. Table 78 summarizes the results of
RCRA quarterly sampling events results for mercury.
117
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September 2017
Table 78: Summary of mercury in groundwater during August 1992 - December 2003
Date | BG
POC-2R
POC-3
NUS-4R
4A
5A
9A
10AR
10BR
11A
11B
13A
14A
Aug-92
0.001
0.001
0.002
!
0.114
--
0.048
0.002
..
Dec-92
0.0002
0.0004
--
--
0.0008
0.0011
0.0152
0.0474
0.0022
-
Mar-93
-
0.0004
--
--
0.0003
--
0.0009
0.02
--
0.045
--
0.002
-
Jun-93
0.006
--
0.0003
0.003
--
0.044
0.0042
Sep-93
--
-
-
--
--
NS
0.1
--
--
--
Dec-93
-
-
-
-
NS
--
-
0.017
-
0.064
-
~
-
Mar-94
--
-
--
--
--
-
0.079
-
0.018
~
0.003
--
Jun-94
--
-
--
0.0045
NA
-
0.0508
0.0045
Sep-94
--
--
-
NA
-
0.06
0.048
--
0.004
Dec-94
--
-
--
--
--
--
--
0.041
--
0.045
--
--
Apr-95
--
--
0.076
-
0.033
0.002
..
Jun-95
-
--
--
-
0.1315
~
0.0369
0.0043
Sep-95
-
--
-
-
~
-
-
0.038
--
0.034
-
0.003
-
Dec-95
--
--
--
0.0108
0.0377
0.0039
Mar-96
~
-
-
--
--
-
0.0438
~
0.0342
0.0032
Jun-96
--
--
-
-
-
0.0093
0.036
Sep-96
-
0.0014
0.076
0.031
Dec-96
-
-
-
--
-
--
0.057
Mar-97
-
--
0.0164
0.0197
--
Jun-97
~
~
--
0.032
-
0.013
Sep-97
-
--
-
NS
~
0.0038
Dec-97
-
-
-
-
NS
NS
-
0.0036
0.0003
Mar-98
--
-
-
-
-
-
--
0.004
0.003
--
Jun-98
-
--
--
-
-
-
0.152
0.012
Sep-98
--
--
--
-
--
--
0.045
NS
0.005
--
Dec-98
-
0.0045
-
...
--
-
NS
NS
0.0087
-
0.0006
Mar-99
-
0.00054
--
--
0.00127
NS
0.00531
0.0006
Jun-99
-
0.00035
--
--
--
-
-
0.00525
--
0.00706
0.00185
Sep-99
-
NS
"
--
-
-
NS
NS
0.015
--
0.0019
Jan-00
0.0017
0.0012
0.0026
0.0007
0.0012
0.0012
0.0045
0.0011
0.0009
0.0011
0.0007
0.0031
0.0022
Mar-00
-
0.0008
0.0002
0.0107
0.0019
Jun-00
-
--
--
-
--
-
Sep-00
~
--
--
-
--
-
--
-
Dec-00
--
0.0007
--
--
NS
-
0.0006
0.0003
--
0.0137
-
0.0023
Mar-01
-
0.0002
--
--
NS
0.0003
0.0003
--
0.0113
0.0021
Jun-01
--
-
--
-
--
NS
0.0004
-
0.0149
...
0.0017
Sep-01
--
-
-
-
-
-
--
0.0004
--
0.0152
0.0004
0.0018
-
Dec-01
--
~
--
--
NS
--
-
--
0.0039
Mar-02
-
-
-
NS
--
-
0.0051
0.0006
Jun-02
-
-
-
-
NS
--
-
--
-
0.0071
--
Sep-02
-
--
--
-
NS
-
-
0.0079
0.0007
Dec-02
-
-
-
--
NS
-
--
-
--
Mar-03
-
-
--
--
NS
-
-
-
0.0023
0.0007
Jun-03
-
-
-
--
NS
-
--
-
0.0056
0.00071
Sep-03
-
-
--
--
NS
0.026
0.0005
Dec-03
-
-
-
-
NS
-
--
--
0.0044
0.0003
% Exceed 2L only
2.2%
2.2%
0.0%
0.0%
2.2%
2.2%
4.3%
4.3%
2.2%
2.2%
2.2%
8.7%
0.0%
% Exceed MCL
0.0%
2.2%
2.2%
0.0%
2.2%
0.0%
4.3%
47.8%
0.0%
89.1%
0.0%
32.6%
2.2%
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September 2017
Notes:
All concentrations are in milligrams per liter (mg/L)
Only wells with atleastone detection of mercury are included in this table.
= not detected
NS = not sampled
2L = Title ISA North Carolina Administrative Code Subchapter 2L Groundwater Standards (I5A NCAC 2LStandard2
MCL = Safe Drinking Water Act's Maximum Contaminant Level
concentration exceeds 2L value for mercury (0.0011 mg/L) but is less than the Ma (0.002 mg/L)
concentration exceeds MCL for mercury (0.002 mg/L)
The wells with frequent detections of mercury at concentrations above drinking water standards were
UNPA wells 10AR, 11A and 13 A. Figure 26 illustrates the locations of these wells. Wells 10AR and
13A are on the east side of the North Retention Basin and well 11A is located north of the former North
Pond.
Figure 26: Locations of wells 10AR, 11A and 13A
Detected mercury concentrations in wells 10AR and 13A dropped below drinking water standards in
March of 2000 and December 2001, respectively. Detected mercury concentrations in well 11A dropped
from 0.1 mg/L in 1993 to only slightly above the MCL in 2002 through 2003. Figure 27 illustrates the
trend of mercury concentrations in groundwater over time for well 11 A. The mercury concentration in
11A has decreased significantly over time, trending to non-detect.
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Figure 27: Graph of mercury concentrations over time from well 11A
DATE SAMPLED
Illustration 4-2-Graph of Hg concentrations in groundwater over time from well 11.4
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5.6.6.2 CERCLA Groundwater Monitoring Data
Under CERCLA authority, four groundwater sampling events have occurred and the results are
discussed in the following three subsections.
5.6.6.2.1 April 2002 Sampling Event
Groundwater samples were collected during the iESI/RA from temporary wells in six locations in the
UPA and two background locations. Unfiltered samples were analyzed for TAL metals; TCL VOCs;
SVOCs, PCBs, pesticides, and inorganics.
Three VOCs and nine inorganics were detected at concentrations that exceeded drinking water
standards. SVOCs were present at concentrations below drinking water standards. The laboratories did
not detect PCBs or pesticides.6 Table 79 summarizes results that had a detectable concentration that
exceeded a State or Federal drinking water standard. Figure 28 illustrates the sample locations.
6 Arodor 1268 was not included in the list of PCBs analyzed.
121
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September 2017
Table 79: Constituents with Results Greater than Drinking Water Standards in April 2002 Sampling Event
Analyte
Standard
HC-01
HC-03
HC-04
HC-05
HC-07
HC-09
HC-23
HC-24
2L
MCL
On-Site
Baclq
ground
Retort Area
Fill Area
Robert's
Pond
Off-site
Old
Parking
Area
VOCs (ng/L)
1,1-dichloroethane
6
NE
25
13
18
5
NA
trichloroethene
3
5
3
1
2
NA
--
-
vinyl chloride
0.03
2
8
9
13
4
--
NA
-
--
INORGANICS (ng/L)
aluminum
NE
50*
26,000
190
34,000
4,900
6,300
900
4,500
3,900
arsenic
10
10
190
110
170
33
20
22
beryllium
NE
4
--
6.4
cadmium
2
5
1.2
2.9
1.7
--
chromium
10
100
99
NA
78
9.6
16
8.6
3.6
11
iron
300
NE
3,000
410
3,200
3,100
6,400
4,400
5,700
31,000
mercury
1
2
24
0.67
14
0.96
6.4
2.4
-
manganese
50
NE
44
35
34
320
360
66
30
480
thallium
NE
2
NA
NA
NA
6.4
--
NA
Notes:
* Secondary MCL, not enforceable
2L = Title 15A North Carolina Administrative Code Subchapter 2L Groundwater Stan da rds (I5A NCAC 2L Sta nda rd)
-- = not detected
MCL = Safe Drinking Water Act's Maximum Contaminant Level
NA = not analyzed
NE = not established
concentration exceeds 2L value but is less than the MCL
concentration exceeds MCL value
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Summary of Remedial Alternative Selection
September 2017
Figure 28: Exceedances in groundwater from April 2002 sampling event
123
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Record of Decision
LCP-Holtrachem Superfund Site
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5.6.6.2.2 December 2004 and April 2009 Sampling Events
Site-wide groundwater sampling events occurred as part of the EE/CA-RI in 2004 and 2009. During
each event, the groundwater samples were analyzed for TAL metals, TCL VOCs, SVOCs, PCBs +
Aroclor 1268, pesticides, and inorganics.
A summary of the detected constituents and their 2L Standards, MCLs and SMCLs, where available, for
the 2004 and 2009 sampling events are presented in Table 80 and Table 81 respectively.
Table 80: Summary of Detected Constituents - 2004 Groundwater
Table 4-17
Summary of Detected Constituents 2004 Groundwater
Rl Report
LCP-Holtrachem Site, Riegelivood, NC
General Sit# Location
UPA
II ^
#A
Woodad Bottomland Area
Regulatory Standard & Sample ID
2L
MCL
BQ
MW-15
MW-16
WW-17
MW-18
MW-18
MW-20
mw-21
POC-2R
14A
P0C4
NUS-4R
6A
88
Parameter Name
Unit*
Method
2004 |
2004
2004
2004
2004
2004
2004
2004
2004
2004 II 2004
2004
2004
2004
ReldpM*
S.U.
150.1
6.5-8 5
65-8.5''
5.9
9.36
8.7
5.84
101
637
6*6
5J9
657 '
8.78 || *21
75
6.77
62
Hi
S.U. |
9040B
6 5-85
65-8.5"'
75
10.2
9.2
65
72
7.5
6.9
8.3
6.9
7
6.7
TJ
7.4
6.5
chloride
mgJL
300.OA
250
250^'
864
196
216
1060
7870
28800
3210
16000
2770
2520
2960
286
245
2470
NITROGEN. NITRATE (AS N)
mg;L
300.0A
10
10
0JU 1
10U
5U
5U
SU
356
NA
3.88
0.5U
0.5U
Q.5U
0.5U
0.5U
0.5U
SULFATE
mg/L
300.0A
250
250^'
26.9
953
212
3450
588
1280
48.2
376
160
129
785
240
592
166
ALPHA-CHLORDANE
ug.l
3061A
0.10
2
0.000335U
0.0064
m
0.00102L
0.00105U
0.1S2
0 00442
0.00232
0.000962U
0.00428
0.000962U
0.00111U
0-00115U
0.0154
BETA-CHLORDANE
ug.t
8061A
0.10
2
0.000456'J
NA
NA
NA
NA
NA
\A
NA
NA
NA
NA
NA
NA
DtELORM
ug,'L
8081A
0.002
NE
0.000267J
>002021
0.04U
Dv05£3
0 000984J
0.00189U
0.00192U
0.00196U
0.00192U
0.00222U
0.0023U
0 00155J
HEPTACHLOR
ufl/L
8081A
0 008
0.4
0.000718U
j001011
0.00102L
0.00105L
0.084'
> c:^
0,2:1-3
1 ¦
:
0.00111U
030115U
0 02"
AROCHLOR-1268
ug/L 1
8082
NE
0.5
0.0136J '
0.0378
0.757E
0 00371J
0.191
0.0227
0.0243
0.00455J
000957j
0.0197U1
0.0195U
0.0199U
0.0075J
0.0137J
BENZO
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Table 81: Summary of Detected Constituents - 2009 Groundwater
Table 4-18
Summary of Detected Constituents - 2009 Groundwater
RI Report
LCP-Holtrachem Stta, Riegelwood, NC
II Wooded Bottomland Area
General Site Location
UPA
UNPA
Regulatory Standard & Sample ID|f *2^ -
MCL
BG
MW-15
MW-18
HW-17
MW-18
MW-19
MW-20
MW-21
POC-2R
11A
14A
POC-3
NUS-4R
B9
Parameter Name
irni'T.Ti
2009
2009
2009
2009
2009
2009
2009
2009
2009
2009
2009
2009
2009
2009
Field pW
S.U
1501
65-85
6.5-8.5f,!
6.72
9.23
8.92
672
742
784
693
6.46
714
8.96
673
6.41
7JJ1
652
pH
8.U.
90406
6.5-8.5
6.5-85"'
NA
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CHLORIDE
mgl
300 OA
250
250*15
64 :
223
i 196
866
1260
17800
1140
10100
1040
6610
2980
3720
41.8
1380
NITROGEN, NITRATE IAS N)
mg/L
300 OA
to
10
0.078
005U
005U
0Q5U
1.6
2.5UG
Q.05U
Q.24J
0.05U
12U
048J
0.5U
0.008J
0.15
SULFATE
mg/L
300.0A
250
250"'
14.5
1320
296
1900
63.7
734
10.7
165
27.3
216
130
960
217
612
NAPHTHALENE
ufl/L
827K
6
NE
0.1911
4.4
0.97U
0.2U
0.19U
121
02U
0.2U
0.19U
0.25
0.15J
0.19U
0.19U
0.19U
ALUMINUM
ug/L
6010B
NE
50-20tr"
30U
2360
27300
255
46200
1140
319
1S0U
413
150U
30U
30U
30U
30U
ANTIMONY
ug/L
6010B
NE
'.5
2U
5.5
14.3
2U
6
15J
2U
10U
2U
2.1J
20
2U
2U
2U
ARSENIC
ug/L
6010B
to
10
1U
784
133
06J
13.7
1U
32
5U
38
5U
1U
m
1U
1U
BARIUM
ug/L
6010B
700
2000
8J
132
68.6
26.7
314
234
56
520
105
9.4J
200
66 2
19.6
66.4
CHROMIUM
ugl
60106
10
100
2U
121
228
2U
2U i
2U
10U
2U
10U
2U
2U
2U
2U
IRON
ug/L
60106
300
3C0'11
3180
11700
2140
22800
900
1040
114J
4340
250U ]
476
179
50U
835
MANGANESE
ug/L
60106
50
50"'
224
86 8
88
360
138
198
158
353
210
2.5U
77.9
147
4.1
117
MERCURY
ug/L
747DA
1
2
0.2U
019J
0.79
0.44
87.8
0.56
0,51
02U
0.2U
0.2U
0.2U
0.2U
0.2U
NICKEL
upL
60106
100
NE
12
33.1
229
1.8
10.4
2.7J
2.6
6.5
3.4
3.9
1U
4.4
SELENIUM
ugfL
60106
20
50
5U
1.9J
I 117 I 5U
12J
04SJ
2.6J
25U
0.96J
2SU
5U
5U
5U
1.4J
Notes
jgfL ¦ micrograms per liter I mg/L * milligrams per liter I wi * Standard Unite! mS/cm * mill Swmen»centimo»er
2L = Title 15A North Carolina Administrative Code Subchapter 2L Groundwater Standards (15A NCAC 2L Standard)
MCL = Maximum Contaminant Lovcl - from EPA's National Primary Drinking Water Regulations (NPDWRs or pnmary
standards).
<11 - National Secondary Drinking Water Standard was used where no National Pnmary Standard was established.
(7) Interim 21 Standard
Shaded & bold values mdicate concentrations that exceed either a 2L or MCL regulatory standard
NE * Not Established
NA * Not Analyzed
QhBss
B - When associated with metals, value is between the contract required detection limit (CRDL)
and instrument detection limit (IDL)
B-When associated with orgamcs. anafytc was also detected in the blank
D - Compound quantitated on a diluted sample
E - Concentration exceeds the ca&) nation range of the instrument
J - Estimated *alue. the result tails between the method detection Itnrt and the limit of quantitation
JN - Estimated maximum possible concentration fEMPC}
U - Not detected, value shown is detection limit
UG-Elevated reporting imit due to matrix interference
N = esrimatod (for metals)
Several contaminants were present in groundwater at concentrations exceeding drinking water standards.
The following paragraphs discuss these results.
Mercury
Figure 29 shows the distribution of mercury in groundwater for the 2004, 2009 and 2012 monitoring
events. In 2004, mercury was present in the following three wells at concentrations exceeding drinking
water standards: MW-18, MW-19, and MW-20. These wells are located in the UPA. No detectable
concentrations of mercury were present in the UNPA or WBA during this event.
In 2009, mercury concentrations for MW-19 and MW-20 dropped to below the drinking water
standards. Wells MW-11A and MW-18 were the only two wells with mercury concentrations in excess
of a standard. The concentrations were 1.2 and 87.8 pg/L respectively. No detectable concentrations of
mercury were present in the WBA during this event.
125
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September 2017
Figure 29: Mercury in Groundwater 2004, 2009 and 2012
W>fm
GRAPHIC SCALE - IN F£ET
MERCURY IN GROUNDWATER MAP (2004. 2009 & 2012)
LCP - HOLTRACHEM SITE
RIEGELWOOD. NORTH CAROLINA
APPROVAL 8WJ DATE.; JANUARY 20)3
SCAL£; A$ SHOWN nC: 4-; 7
Aroclor 1268
Figure 30 shows the distribution of Aroclor 1268 in groundwater for the 2004, 2009 and 2012 monitoring
events. In 2004, Aroclor 1268 was present in several wells, but only one well had a concentration above
the MCL.7 Well MW-16 had an estimated concentration of 0.757 jag/L. In 2009, no detectable
concentrations of Aroclor 1268 were present in groundwater. The laboratory detection limit was below
the MCL.
7 The MCL value for Aroclor 1268 is 0.5 ng/L. There is no 2L standard for Aroclor 1268. https://www.epa.gov/eround-water-
and-drinkine-water/table-regulated-drinking-water-contaminants#Organic
126
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Summary of Remedial Alternative Selection
September 2017
Figure 30: Aroclor 1268 in Groundwater 2004, 2009 and 2012
loS^TSa
GRAPHIC SCALE - IN FEE"'
AROCLOR-1266 IN GROUNDWATER MAP (2004. 2009 & 2012)
LCP - HOLTRACHEM SITE
RIEGELWOOD. NORTH CAROLINA
Pesticides
In 2004, pesticides were present at concentrations exceeding drinking water standards in wells in the
UP A, UNPA and WBA. In 2009, there were no detectable concentrations of pesticides in any of the
groundwater samples. As previously discussed, the annual RCRA sampling results from the three POC
wells did not identify detectable concentrations of pesticides from 1992 to 2003. Previous investigations
did not identify a source of pesticides at the site. Figure 31 illustrates the concentrations of pesticides in
groundwater in 2004 and 2009.
127
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Figure 31: Pesticides in Groundwater 2004 & 2009
PESTICIDES IN GROUNDWATER MAP (2004 £ 2009)
LCP HOLTRACHEM SITE
RIEGELWOOD. NORTH CAROLINA
Metal Indicator Parameters
Figure 32 illustrates the concentrations of metals in groundwater in 2004 and 2009 that exceeded
drinking water standards. The following inorganics were only present in the UPA groundwater at
concentrations above a standard: antimony, arsenic, barium, chromium, nickel and selenium. Iron,
manganese and thallium were present in groundwater above a standard across the site. The 2009 data
indicated iron and manganese were the only metals detected in the WBA above a groundwater standard.
Antimony, arsenic, chromium and nickel were present in wells MW-15 and MW-16 in concentrations
exceeding drinking water standards. These constituents do not appear to be migrating to down gradient
wells as observed in the results from wells MW-17, MW-19 and MW-20.
Arsenic and chromium were present in well MW-18 in concentrations that exceeded drinking water
standards. The 2009 data indicates these constituents are not migrating to the WBA as observed in the
results from down gradient wells MW-19 and MW-21.
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Figure 32: Metals in Groundwater 2004 & 2009
SVOCs
Figure 33 illustrates the concentrations of SVOCs in groundwater in 2004 and 2009 at concentrations that
exceeded drinking water standards. In 2004, three SVOCs were present in well MW-15 at
concentrations in excess of the 2L Standards. SVOCs were not detected in groundwater samples from
the other wells. In 2009, the concentrations of SVOCs detected were less than 2L and MCL standards.
The detected SVOCs do not appear to be migrating towards down gradient wells as observed from well
MW-16. Previous investigations did not identify a source of SVOCs at the site.
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Figure 33: SVOCs in Groundwater 2004 & 2009
¦H
GRAPHIC SCALE - IN FEE"
SEMI-VOLAT1LES IN GROUNDWATER MAP (2004 & 2009)
LCP - HOLTRACHEM SITE
RIEGELWOOD. NORTH CAROLINA
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5.6.6.2.3 September 2012 Sampling Event
The September 2012 sampling event included the collection of groundwater from well P9. Consultants
installed well P9 at the toe of the UPA directly above the observed seep at the head of the central
drainage pathway, as illustrated in Figure 34.
Figure 34: Location ofP9 and Observed Intermittent Seep Area
S
j
\
I \
v
>//%
mYr
TORT PAD
--v ! Approilnwff Arw of /
\ \ Inlcrnittrnt Swp //
Is / V \ ! I ~ / ! J
Mr TVS"
iMl'/
ffJrwtranon 5-J: Intermittent Seep Area
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Filtered and unfiltered groundwater samples were analyzed for mercury and Aroclor 1268. Mercury was
not detected in either sample. Aroclor 1268 was detected at concentrations below the MCL in the
unfiltered sample, but not detected in the filtered sample. The filtered results suggest particulates in the
sample may have affected the detection of Aroclor 1268 in the unfiltered sample. Table 82 summarizes
the analytical results.
Table 82: Groundwater Data for Mercury and Arodor 1268 in September 2012
Analyte
Standard
P-09
unfiltered
P-09
filtered
2L
MCL
W
BA
mercury
1
2
<0.15
<0.15
Aroclor 1268
NE
0.5
0.131
< 0.0651
Notes:
Samples were only analyzed for mercuiv and Aroclor 1268
Concentrations units are milligrams per liter (mg/L)
2L = Title 15A North Carolina Administrative Code Subchapter 2L
Groundwater Standards (I5A NCAC 2L Standard)
MCL = Safe Drinking Water Act's Maximum Contaminant Level
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5.7 Location of Contamination and Routes of Migration
5.7.1 Location of Contamination
Figure 35: Remedial Footprint
Soil. Sediment and Surface Water
The pink shading in Figure 35 illustrates areas that have contaminated soil, sediment and surface water
at concentrations that may pose unacceptable risks to human health and/or the environment.
Contamination depths vary across the site from only at the surface to ten feet or greater below land
surface. It is estimated that there are approximately 75,000 yd3 of contaminated soil, sediment and
WWTS. The surface water becomes contaminated in the drainage pathways that are ephemeral and flow
directly to the river. A calculation of volume of surface water was not estimated due to the variability.
Air
Currently, occasional concentrations of mercury are detected at the site during air monitoring events.
The concentrations do not pose an unacceptable risk to human health or the environment.
Groundwater
Contamination was detected in groundwater in the surficial deposits. The contamination does not pose
an unacceptable risk to human health or the environment. The water table ranges from less than one foot
bgs to 13 feet bgs. No appreciable vertical flow is expected due to low formation permeability in the
Peedee confining unit.
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Groundwater in the surficial deposits at the site cannot be used for potable purposes according to 15 A
NCAC 2C.0107, because potable wells should be cased to a minimum depth of 35 feet bgs.
Groundwater in the Peedee formation at the site cannot be a portable water supply due to its low
permeability and low flow conditions estimated at about 20 gallons per day. Formations beneath the
Peedee are reportedly naturally saline and would not be used for potable water purposes.
Based on multiple criteria, the aquifer does not meet the requirements specified in the EPA "Guidelines
for Ground-Water Classification Under the EPA Groundwater Protection Strategy" to be considered a
drinking water aquifer and is characterized as a EPA Class III, Subclass IIIA, not suitable as a potential
source of drinking water and of limited beneficial use, and the human health and ecological pathways
for groundwater are incomplete. This determination on groundwater is based on multiple lines of
evidence that indicate detected constituents in groundwater are not migrating and that there is no current
or future detriment to human health or the environment by this medium. The evidence supporting this
determination is summarized below:
Former production processes and equipment related to manufacturing that could produce
additional sources of contamination were removed from the site.
The time and direction of travel of the contaminants in groundwater have been projected with
reasonable certainty.
The only adjacent property onto which groundwater contaminants could migrate is the IP
property.
The groundwater data does not indicate site constituents will migrate onto the IP property.
An existing public water supply system for the City of Wilmington, IP, the site, and surrounding
community is dependent on surface water intakes from the Cape Fear River upstream of the site.
The detected groundwater constituents are not expected to reach the Cape Fear River, which is
the nearest downgradient surface water body.
The thickness, hydraulic conductivity, and recharge rates observed for the shallow, perched
aquifer fail to meet the minimum productivity requirements for it to be a drinking water aquifer.
5.7.2 Potential Routes of Current and Future Migration
Figure 9 on page 20 illustrates the Conceptual Site Model showing migration pathways. Potential current
and future migration of contaminants could occur via
overland flow of rain water that may transport contaminated soil and/or sediment to the WBA
and Cape Fear River,
permitted discharges of water to the Cape Fear River,
potential damage to the Engineered Stockpiles, retention basins, etc. from a hurricane or tropical
storm,
atmospheric deposition, and
leaching of contaminants into groundwater.
Rainwater Migration Pathway
Contaminated sediment within the drainage pathways is likely to be mostly immobile during low flow
conditions and mobile during high flow conditions. Examples of high flow conditions include heavy
precipitation or flooding events. The drainage pathways discharge uncontrolled storm water and
possibly soil and sediment run-off into the Cape Fear River.
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In June and August 2006, surface water samples were collected from drainage pathways during two
extreme rain events. These two rainfall events had more rain than 91% and 99.95% of other rainfall
events recorded at the U.S. Geological Survey's gauge for that year. The results for the eastern and
central ditches indicate the storm water samples fall within the same range of the surface water
concentrations for these two ditches. The western ditch results indicate the largest change in
concentrations, where each of the compounds detected were higher for the storm water samples than the
surface water samples. The Total Suspended Solids (TSS) concentration for the western ditch for the
storm water results was also higher, suggesting a more turbid sample compared to the surface water
samples. The data provides some indication that contaminated sediment in the drainage ditches may
become mobile during storm events or flooding.
Permitted Discharges
The facility treats collected storm water and then sends it to IP. IP has an NPDES permit to discharge its
treated water to the Cape Fear River. Contamination may migrate via this permitted discharge.
Hurricane and/or Tropical Storm Damage
The site has been affected by numerous hurricanes and tropical storms. A plan is currently in place to
prepare for such events to minimize damage. However, there currently remains a potential that a major
storm could cause damage to the Engineered Stockpiles, retention basins, stored chemicals used in the
waste water treatment process, etc.
Atmospheric Deposition
Air monitoring is conducted at the facility frequently for mercury. Since the Engineered Stockpile #1
was placed on top of the former Mercury Cell Building, the concentrations of mercury detected in the air
have reduced drastically. This migration pathway is minimal.
Leaching to groundwater
In general, the potential soil to groundwater transport mechanism is chemical leaching of constituents
from soils or waste disposal areas, and transport through the shallow vadose zone to the water table. The
two primary contaminants, mercury and Aroclor 1268, strongly sorb to soils at the site limiting their
ability to leach. The groundwater data does not indicate site constituents will migrate onto the IP
property or into the Cape Fear River. The transport of contaminants in groundwater is also restricted by
the Peedee Formation confining unit.
Mercury is strongly sorbed to humic materials and sesquioxides in soils and sediments at a pH higher
than four and to the surface layer of peat. Mercury is also sorbed to sediments and soils with high iron
and aluminum content, which has been readily observed at the site. Once sorbed to soil and particulate
material, inorganic mercury is often not readily desorbed.
The ability of PCBs to be degraded or transformed in the environment depends on the degree of
chlorination of the biphenyl molecule as well as on the isomeric substitution pattern. Aroclors 1254 and
1268 are some of the more chlorinated compounds in the PCB family, they strongly sorb to soil as a
result of their low water solubility and high Kow.8 Subsequently, this condition greatly limits these
Aroclors ability to leach in soils. Higher clay and organic content, such as is the case with much of the
site soil, also substantially reduces leaching of these Aroclors into groundwater.
8 Kow is the octanol: water distribution coefficient.
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6.0 CURRENT AND POTENT! U. FUTURE LAND AM) RESOURCE USES
The facility ceased operations in 2000. Currently, the site use is limited to security, maintenance and
storm water management. The majority of Columbus County, including the site property, is zoned
"General Use",9 The site and immediately surrounding property to the south, east and west include
industrial facilities. The Cape Fear River borders the north side of the site. Property north of the Cape
Fear River is undeveloped low-lying land. The closest residential property is located about i s
southwest, just outside the IP property boundary.
IP and the City of Wilmington use the Cape Fear River as a source for drinking water. IP maintains a
surface water intake about Vi-miie west (upstream) of the site, where they draw river water into the
Riegelwood Mills water treatment facility for local distribution. The City of Wilmington maintains a
surface water intake 8.3 miles upstream of the site. People also use the Cape Fear River near the site
recreationally.
Reasonably anticipated future land use of the site is industrial/vacant. Heavily industrialized IP is a
thriving business that surrounds the site on three sides, EPA anticipates that the current land use will
remain in place. Based on multiple criteria, the aquifer is characterized as an EPA Class III, Subclass
III A, not suitable as a potential source of drinking water and of limited beneficial use per "Guidelines
for Ground-Water Classification Under the EPA Groundwater Protection Strategy", and the human
health and ecological pathways for exposure to contaminated groundwater are incomplete. Data
indicates that detected constituents in groundwater are not migrating and are not causing detriment to
human health or the environment.
9 http://rnanRomap.com/ma
)lumbus-Countv-Zoning#
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Figure 36: Columbus County Zoning
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7.0 SUMMARY OF SITE RISKS
The response action selected in this ROD is necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances into the environment.
7.1 Human Health Risk Assessment
The baseline risk assessment estimates what risks the site poses if no action were taken. It provides the
basis for taking action and identifies the contaminants and exposure pathways that the remedial action
needs to address. This section of the ROD summarizes the results of the baseline risk assessment.
7.1.1 Identification of Chemicals of Concern
The following three tables present the chemicals of concern (COCs) and exposure point concentration
(EPC) for each of the COCs detected in surface soil, subsurface soil and surface water, respectively.
They also include the range of concentrations detected for each COC, the frequency of detection (i.e.,
the number of times the chemical was detected in the samples collected at the site), and how the EPC
was derived. EPC is the concentration that is used to estimate the exposure and risk from each COC.
Sediment, groundwater and air data did not indicate risks to human health; therefore, only surface soil,
subsurface soil and surface water are included in the tables.
The data indicates that Aroclor 1268, mercury, and 2,3,7,8-TCDD TEQ are the most frequently detected
COCs in soils and surface water at the site. Aroclor 1254 and benzo(a)pyrene are less frequently
detected, but contribute towards risks posed to human health.
Table 83: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Surface Soil
Scenario Timeframe: Current/Future
Medium: Soil
Exposure Medium: Surface Soil (0-1 foot)
Exposure
Point
Concentration Detected
Frequency of Detection
Exposure Point
Statistical
Measure
Chemical of Concern
Minimum*
Maximum*
Percent
Number of
Samples
Concentration
Upland Area
Surface Soil
Aroclor-1268
0.016, J
2,700.
99%
82/83
2,600
95% UCL-t
benzo(a)pyrene
0.036|J
26. D
28%
17/61
3.5
97.5% Cheb-m
mercury
0.0184;j
1,300
99%
196/197
2,800
99% Cheb-m
Wooded
Aroclor-1254
0.0045:J
67
46%
19/41
20
99% Cheb-m
Bottomland
Aroclor-1268
0.098
3,800
100%
39/39
1,300
97.5% Cheb
Area Surface
2,3,7,8-TCDD TEQ (dioxi ns/furans)
0.00000115;
0.001384
100%
29/29
0.0013
97.5% Cheb
Soil
2,3,7,8-TCDD TEQ (PCBs)
0.00000032
0.000282
100%
29/29
0.00014
95% Cheb
Notes:
* = Concentrations are expressed in parts per million (ppm). In this table ppm = milligrams per kilogram (mg/kg)
Cheb = Chebyshev Mini mum Variance Unbiased Estimate (MVUE) of Upper Confidence Limit (UCL)
Cheb-m = Chebyshev (mean,std) Upper Confidence Limit (UCL)
D = result reported from dilution
J = compound was detected below the reporting limit in the sample
PCBs = polychlorinated biphenyls
TCDD TEQ=tetrachlorodibenzo-p-dioxin toxicity equivalent quotient
UCL-t = Upper Confidence Limit of Log-transformed Data, H-Statistic
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Table 84: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Subsurface Soil
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Subsurface Soil (l-10feet)
Exposure
Point
Chemical of
Concern
Concentration Detected
Frequency of Detection
Exposure Point
Concentration
*
Statistical
Measure
Minimum*
Maximum*
Percent
#of
Samples
Upland Area
Subsurface
Soil
Aroclor-1254
0.0074 J
5.1
25%
25/101
3
97.5% Cheb-m
Aroclor-1268
0.0036 J
2,700
96%
224/233
2,900
99% Cheb-m
mercury
0.00822 J
11,000X
99%
343/348
4,400
99% Cheb-m
Notes:
* = Concentrations are expressed in parts per million (ppm). In this table ppm = milligrams per kilogram (mg/kg)
Cheb-m = Chebyshev (mean,std) Upper Confidence Limit(UCL)
J = compound was detected below the reporting limit in the sample
X = sample contained beads of mercury
Table 85: Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations for Surface Water
Scenario Timeframe: Current/Futu re
Medium: Surface Water
Exposure Medium: Wooded Bottomland Area Drainage Pathway Surface Water
Exposure
Point
Chemical of Concern
Concentration Detected
Frequency of Detection
Exposure Point
Concentration
*
Statistical
Measure
Minimum*
Maximum*
Percent
# of
Samples
Surface
Water
Aroclor-1268
0.062
17
80%
12/15
4.4
App. Gamma
Total 2,3,7,8-TCDDTEQ(dioxin/furan)
3.34E-06;
3.38E-04,
100%
6/6
3.40E-04
Max
Total 2,3,7,8-TCDD TEQ (PCB)
3.20E-06
1.19E-04
100%
4/4
1.20E-04
Max
Notes:
* = Concentrations are expressed in parts per billion (ppb). In this table ppb = micrograms per liter (ug/L)
App. Gamma = Approximate Gamma
J = compound was detected below the reporting limit in the sample
Max = Maximum Detected Value
TCDD TEQ=tetrachlorodibenzo-p-dioxin toxicity equivalent quotient
7.1.2 Exposure Assessment
EPA risk assessment guidance documents and professional judgement were used to determine exposure
intakes from soil, indoor air and surface water. These were based on the Conceptual Site Model (Figure 9
on page 20). There is not an exposure pathway for groundwater. Potentially exposed populations include
current and future trespassers, recreators, and anglers, as well as future industrial and construction
workers.
The HHRA included both reasonable maximum exposure (RME) and central tendency exposure (CTE)
intake calculations. RME intakes protect 95% or greater of the study population, while CTE intakes
address moderate or median exposure scenarios. The HHRA discussed CTE intakes and related risk
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calculations in the Uncertainties section, used primarily as supplemental information and a risk
management tool.
7.1.3 Toxicity Assessment
In the HHRA, the hierarchy of sources used for toxicity values was:
1) Integrated Risk Information System (IRIS),
2) Provisional Peer-Reviewed Threshold Values (PPRTVs) as presented in the Region 9 Preliminary
Remediation Goal (PRG) Table, and
3) other sources such as the Human Effects Assessment Summary Tables (HEAST), National Center
for Environmental Assessment (NCEA), and California EPA values as presented in the Region 9
PRG Table.
Oral reference doses (RfDs) and cancer slope factors (CSFs) were revised in accordance with Risk
Assessment Guidance for Superfund (RAGS) Part E guidance. The HHRA provided a brief toxicity
profile of mercury, PCBs, and dioxins furans.
7.1.4 Risk Characterization
For carcinogens, risks are generally expressed as the incremental probability of an individual developing
cancer over a lifetime as a result of exposure to the carcinogen. Excess lifetime cancer risk is calculated
from the following equation:
Risk = CDI x SF
where: risk = a unitless probability (e.g., 2 x 10'5) of an individual developing cancer
CDI = chronic daily intake averaged over 70 years (mg/kg-day)
SF = slope factor, expressed as (mg/kg-day)'1.
These risks are probabilities that usually are expressed in scientific notation (e.g., lxl0"6). An excess
lifetime cancer risk of lxl0"6 indicates that an individual experiencing the reasonable maximum
exposure estimate has a 1 in million chance of developing cancer as a result of site-related exposure.
This is referred to as an "excess lifetime cancer risk" because it would be in addition to the risks of
cancer individuals face from other causes such as smoking or exposure to too much sun. The chance of
an individual's developing cancer from all other causes has been estimated to be as high as one in three.
EPA's generally accepted risk range for site-related exposures is 10"4 to 10"6.
The potential for non-carcinogenic effects is evaluated by comparing an exposure level over a specified
time period (e.g., life-time) with a reference dose (RfD) derived for a similar exposure period. An RfD
represents a level that an individual may be exposed to that is not expected to cause any deleterious
effect. The ratio of exposure to toxicity is called a hazard quotient (HQ). A HQ less than 1 indicates that
a receptor's dose of a single contaminant is less than the RfD, and that toxic non-carcinogenic effects
from that chemical are unlikely. The Hazard Index (HI) is generated by adding the HQs for all
chemical(s) of concern that affect the same target organ (e.g., liver) or that act through the same
mechanism of action within a medium or across all media to which a given individual may reasonably
be exposed. A HI less than 1 indicates that, based on the sum of all HQ's from different contaminants
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and exposure routes, toxic non-carcinogenic effects from all contaminants are unlikely. A HI greater
than 1 indicates that site-related exposures may present a risk to human health.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RJD
where: CDI = Chronic daily intake
RfD = reference dose.
CDI and RfD are expressed in the same units and represent the same exposure period (i.e., chronic,
subchronic, or short-term).
The HHRA identified cancer risks and non-cancer hazards. The following paragraphs summarize the
estimates for each receptor:
Industrial Worker - Upland Surface Soil Exposures: Arsenic, six carcinogenic PAHs, dioxins, furans,
and PCBs were associated with estimated carcinogenic risk greater than 10"6. Mercury and Aroclor 1268
had hazard indices greater than 0.1. The primary exposure pathways were dermal absorption and
ingestion of soil.
Industrial Worker - Indoor Air Exposures: VOCs in indoor air were associated with risks ranging from 1
x 10~5 in the Air Compressor Building to 8 x 10"5 in the New Cell Building. COCs per locations include
Air Compressor Building: benzene, chloroform and trimethylbenzene;
New Cell Building: benzene, chloroform, tetrachloroethene, trichloroethene, and vinyl chloride;
Office Building: benzene and chloroform;
Prep Building: benzene and chloroform
Trimethylbenzene and bromomethane were also estimated to have inhalation hazard indices greater than
0.1.
Hazards associated with mercury in ambient air (which were assumed to be mercury salts and not
elemental mercury based on the sampling locations) were addressed by considering inhalation exposures
to soil particulates and volatiles for industrial workers, construction workers, and trespassers. Calculated
hazard indices for mercury by the inhalation pathways were well below one.
Detected concentrations of mercury and VOCs were either less than current industrial air Regional
Screening Levels or are within the national background range for residential properties. Thus, these data
do not indicate a risk from the vapor intrusion pathway.
Trespasser - Upland Surface Soil Exposures: Risk greater than 10"6 was associated with benzo(a)pvrene,
dibenzo(a.h)anthracene, dioxins, furans, and PCBs in surface soils. Mercury and Aroclor 1268 were
associated with hazard indices greater than 0.1. The primary pathways were dermal absorption and
ingestion.
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Construction Worker - Upland Surface and Subsurface Soil Exposures: Risk greater than 10"6 was
associated with benzo(a)pvrene, iron, mercury. Aroclor 1254 and Aroclor 1268 were associated with
hazard indices greater than 0.1. The primary pathways were dermal absorption and ingestion.
Trespasser Recreator - Bottomland Surface Soil Exposures: Dioxins furans and PCBs were associated
with risk greater than 10"6. Aroclor 1254 and Aroclor 1268 were associated with hazard indices greater
than 0.1.
Surface Water Exposures: By the dermal pathway, dioxins furans and PCBs were associated with risk
greater than 10"6. Aroclor 1254 and Aroclor 1268 had hazard indices greater than 0.1.
Resident Angler - Fish ingestion from the Cape Fear River: DDD, DDE, DDT, Aldrin, dieldrin,
alphachlordane, gamma-chlordane, and bis-2-ethvlhexylphtlialate were associated with risk greater than
10"6. Dioxins, furans and PCBs were associated with risks greater than 10'6. DDD and Aroclor 1268
were associated with hazard indices greater than 0.1.
7.1.5 Uncertainty Analysis
The HHRA includes a discussion of uncertainty associated with the data evaluation, exposure
assessment, toxicity assessment, and risk characterization. Below are the primary uncertainty factors in
this HHRA.
Limited data were available to model congener dioxins furans and PCB concentrations from surface
water to fish tissue, resulting in a high degree of uncertainty. In particular, although only
octachlorodibenzo-p-dioxin (OCDD) was detected in surface water, the HHRA assumed that the other
congeners of dioxins, furans, and PCBs were present at the sample-specific detection limits. As a result,
less than 1% of the estimated risk is associated with detected OCDD in surface water. If the other
congeners were not included in the risk characterization, the estimated risk would not have exceeded 10"
6. In addition, the HHRA discounted mercury data prior to the risk characterization because of data
quality issues. This approach for mercury may have resulted in an underestimation of hazards for fish
ingestion.
There is uncertainty associated with mercury concentrations in Upland Area soils. The sampling team
visually observed mercury beads at the Retort Pad area and former Cell Building area, but collected
limited soil samples where they observed beaded mercury. Thus, the overall mercury concentrations in
upland soils may be underestimated.
Risk characterization based on RME scenarios is conservative and may serve to overestimate risks
associated with site media. However, use of the moderate CTE scenarios did not significantly reduce the
hazards or risks noted with the RME scenarios.
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7.2 Ecological Risk Assessment
The ecological risk assessment is a multi-step process. The assessment was completed in accordance
with Ecological Risk Assessment Guidance for Superfund: Process for Designing and Conducting
Ecological Risk Assessments (EPA 1997), NCDENR's Guidelines for Performing Screening Level
Ecological Risk Assessments within the North Carolina Division of Waste Management (NCDENR
2003) and the Baseline Ecological Risk Assessment Work Plan and Sampling and Analysis Plan (CH2M
HILL 2009).
The documents prepared that are part of the ecological risk assessment include:
Ecological Risk Assessment Step 1 through Step 3(a), LCP-Holtrachem Site, Riegelwood, NC
(March 2006),
Ecological Risk Assessment Revised Step 3a. LCP-Holtrachem Site, Riegelwood, NC (January
2008),
Baseline Problem Formulation Step 3b. LCP-Holtrachem Site. Riegelwood, NC (February 2009;
revised September 2009), and
Baseline Ecological Risk Assessment for LCP-Holtrachem Site, Riegelwood, NC (September
2010).
During the risk assessment process, constituents of potential concern, ecological habitats, and
representative ecological receptors were identified. For each representative ecological receptor group,
measurable assessment endpoints were formulated and potential risks were then estimated for each
endpoint. EPA approved the Baseline Ecological Risk Assessment (BERA) in October 2010. A
summary of the process results follows.
7.2.1 Assessment Endpoints
The following receptor groups were evaluated in the BERA:
Soil invertebrates
Insectivorous birds (terrestrial)
Insectivorous mammals (terrestrial)
Herbivorous birds (terrestrial)
Herbivorous mammals (terrestrial)
Amphibians and reptiles (aquatic terrestrial)
Omnivorous birds (aquatic terrestrial)
Omnivorous piscivorous birds (aquatic terrestrial)
Insectivorous piscivorous mammals (aquatic and terrestrial)
Benthic macroinvertebrates
7.2.2 Constituents of Potential Ecological Concern
During Step 3 a, a refined screening for constituents of potential ecological concern (COPECs) was
completed using supplemental toxicological benchmarks and a weight of evidence (WOE) approach.
The WOE approach includes consideration of the magnitude of potential risk, background data,
frequency of detection, frequency of exceedances over screening levels, and bioaccumulation potential.
The list of COPECs identified in Step 3a is summarized in Table 86.
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Table 86: Lower Trophic Level Final Direct Toxicity COPECs
Soil
Sediment
Surface water
Stormwater
Upland and
Bottomland
Bottomland
Drainage Ditches
Cape Fear River
Bottomland
Drainage Ditches
Cape Fear River
Bottomland
Drainage
Ditches
Chromium
Mercury
Mercury
Atuminum
AHmrartum
Alunmnum
Manganese
Aroclor-1016*
Aroctor-1016*
Arsenic
Barium
Cadmdum
Mercury
Aroder-1221*
Anoctor-1221'
Barium
Iron
Copper
Vanadium
Aroctor-1232*
Aroctor-11232*
Cadmium
Lead
Iron
Aroclor-1016*
Aroctor-1242*
Aroctor-1242*
Chromium
Manganese
Manganese
Aroolor-122r
Aroctor-1248*
Aroctor-H246'
Iron
Silver*
Mercury
Aroclor-1232*
Anoctor-1254
AiocCoM254
Lead
Thallium
Stiver
I Aroclcir-1242*
Aroctor-1260*
Aroctor-1260*
Manganese
Vanadium
Vanadium
Aroclor-1248*
Aroctor-1268
Aroclor-1268
Mercury
Zirtc
Zirtc
Anocior 1254
4,4'-DDD
4,4'-DDO
Nickel
Arcctoi 1266
Aroclor 1268
Anoclor 1260*
4,4-DDE
4,4'-DD£
Setenium
4,4--ODD
Methoxyehlor"
Anoclor 1263
4,4'-DDT
4,4'^DT
Silver
4,43-0DE
Toxaplrero*
4.4'-DDD
Chtordane
(tectiriscalj*
DceCdrin
Vanadi um
4,4'-DDT
4.Qhtaro-3-
methylphenor
4,4'-DDE
Dteldrin
Endrin
Zinc
AStftin
Anthracene*
4,4'-DDT
Eitdrin
gatnma-BHC
{Lindane]"
DIoxins/PCBs
TEQs - mammals,
birds, and fish
Qretdrin
Ben2o(a)pyreneT
beta-BHC
gaiwrs-BHC
(Lindane)
Heptachtor
epoxide*
Total Dioxin/ Furan/
PCS 2.3.7.B-TCDD
TEQs - mammal,
bads, and fish
Bndoaifan 0
Benzc{b)
ftuoranthene"
Dieldrin
Heptacfifor epoxide
Toyaptiene*
Arodor-1(M6*
BndosuHan III
Benzo(ghi)
perylerte*
Ertdrnn
Taxapheroe"
Qnfordarte
{technical)*
Arodor-1221*
Endoeutfan
sulfate
Benzo(k)
fluoranthene*
gamma- BHC
(Imttsne)
Aceriaphthene
Dtoxins TEQs -
mammals
Aroclor-1232*
Endrin
Heotachtoro-
butadlerte*
During Step 3b, the COPECs were refined for inclusion in the BERA. In the first step of the refinement,
concentrations of soil COPECs were compared to background. Next, wildlife No Observed Adverse
Effects Level (NOAEL) and Lowest Observed Adverse Effects Level (LOAEL) PRGs were calculated
for the detected COPECs and concentrations of COPECs were compared to PRGs as a way of evaluating
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risk. Concentrations of total mercury exceeded PRGs for methylmercury and mercuric chloride at the
majority of soil sampling locations. Zinc also exceeded PRGs in nearly every soil sample.
Only in isolated areas did other COPECs exceed PRGs. Other COPECs exceeding PRGs consistently
coincided with locations where mercury and zinc exceed their PRGs. COPECs were also compared to
soil and benthic benchmarks and sediment from the Cape Fear River were compared to both wildlife
PRGs and invertebrate benchmarks.
After the results of this analysis in Step 3b, it was decided that the BERA would focus on mercury
compounds with additional analysis of zinc. Although other COPECs did exceed wildlife PRGs across
multiple stations, the focus of the BERA was on mercury and zinc. Most instances of elevated detections
of mercury and zinc coincided with elevated levels of these additional COPECs. Future remediation of
these areas for mercury and zinc would likely remove the majority of the elevated detections of other
less frequently detected COPECs. The final list of COPECs carried into the BERA included
methylmercury, mercuric chloride, mercuric sulfide, and zinc.
7.2.3 Site Investigations in Support of the BERA
7.23.1 Terrestrial
Site investigation activities were conducted in Bottomland Area soils within Terrace A, the Upland Non-
Process Area, and Wetland B. Due to the drier characteristics of the majority of Wetland B, the substrate
is considered soil from an ecological exposure perspective. Media collected included soil and
invertebrate and plant tissue. Toxicity tests were conducted on site soils. Community surveys of
invertebrates were also completed.
Five surface soil samples were collected from each study area (15 total samples). Samples were
analyzed for metals, mercury analysis, TOC, and pH. Six of the 15 samples were also analyzed for grain
size. Mercury analyses included total mercury, methyl mercury, and fractions 1, 2, and 5. In addition,
inorganic divalent mercury (mercury 2+) was also analyzed since this oxidized form of elemental
mercury is the dominant form in the environment.
Plants and soil invertebrates were collected within 5 feet of the 15 soil samples, with the exception of
UNP-5. Only plants could be collected at UNP-5. Plant and invertebrate species collected were those
typically consumed by wildlife living at the site. Plant and invertebrate samples were analyzed for total
mercury, methylmercury, mercury 2+, and zinc.
Laboratory toxicity testing (28-days) was completed for 9 soil samples (i.e. 3 from each study area). The
test organism was the adult stage earthworm Eisenia fetida. Study endpoints were survival and growth.
Similar toxicity testing was conducted in the reference area soil. At the conclusion of the toxicity tests,
earthworms were depurated and the tissue was analyzed for total mercury, methylmercury, mercury 2+,
and zinc.
A soil invertebrate survey was conducted at each soil sample location. An undisturbed area within 5 feet
of the sample location was chosen for the survey. Invertebrates were first collected from leaf litter. Once
leaf litter was cleared, a 1 square foot hole was dug six inches deep. Soil invertebrates in the hole were
collected, counted, and identified.
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A soil reference sample location SOREF-1 was collected in the same area as the Phase II sampling in
November 2005. The reference sample was analyzed for metals, mercury fractions, VOCs, pesticides,
PCBs, SVOCs, pH and TOC. Reference soil was used for toxicity testing of earthworms; however,
earthworm tissue was not analyzed at the end of toxicity testing. A soil invertebrate survey was also
conducted.
Figure 37: BERA Sampling Locations
7.2.3.2 Aquatic
Site investigation activities were conducted for Streams A and B10 and the Cape Fear River. No fish or
larval amphibians were observed within Streams A and B or the other streams on-site.11 Media collected
included surface water and sediment. Toxicity tests were conducted on collected sediments.
Three surface water samples were collected within Wetland B. An independent laboratory analyzed the
samples for metals (filtered), total mercury, methylmercury, mercury 2+, pesticides, SVOCs, PCBs, pH,
and hardness. Contractors collected temperature, pH, and dissolved oxygen data in the field. Three
sediment samples (0-6 inches in depth) were collected within Wetland B. Samples were analyzed for
metals, methylmercury, mercury fractions, pesticides, PCBs, and SVOCs.
10 Streams A and B are also collectively referred to as the western drainage pathway in other portions of the ROD.
11 "Streams on-Site" refer to the ephemeral drainage pathways in the wooded bottomland areas.
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Two types of toxicity testing were conducted for site surface water and sediment. In the first toxicity
test, the larval green frog (Rana clamitans) was exposed to bulk sediment and surface water for 30-days.
The endpoints were mortality, percent malformation and growth. At the termination of the toxicity test,
tadpole tissues were analyzed for total mercury, methylmercury, and mercury 2+ for bioaccumulation
analysis. In the second test, neonate amphipods (Hyalella azteca) were exposed to bulk sediments for
28-days. Endpoints were mortality and growth.
A benthic invertebrate survey was conducted at each sediment sample location using the kick-net
method. Invertebrates in the sediment were collected, counted, and identified.
An off-site upgradient stream was sampled to provide background information on aquatic media.
Surface water from the reference stream was analyzed for metals (dissolved), total mercury,
methylmercury, mercury 2+, VOCs, SVOCs, pesticides, PCBs, pH, and hardness. Reference sediment
was analyzed for mercury, methylmercury, mercury fractions, VOCs, SVOCs, pesticides, and PCBs.
Reference water and sediment samples were used for toxicity testing, and a benthic invertebrate survey
was also completed as described above.
7.2.4 Exposure Analysis
The exposure analysis considered direct exposure by lower trophic-level organisms (e.g. benthic
macroinvertebrates) to constituents in soil, surface water, and sediment. Likewise, the risk associated
through the food web was considered for receptor of concern representing the assessment endpoints.
Food web exposure includes the exposure of upper trophic-level receptors to COPECs in soil, surface
water, and sediment through direct ingestion (intentional or inadvertent) and consumption of prey items
with COPEC body burdens.
The following species were selected to represent receptors of concern in the food web modeling:
Carolina wren - insectivorous bird (terrestrial)
Short-tailed Shrew - insectivorous mammal (terrestrial)
Purple Finch - herbivorous bird (terrestrial)
Meadow Vole - herbivorous mammal (terrestrial)
Bullfrog and Northern Water Snake - Amphibians and Reptiles (aquatic terrestrial)
Wood Duck - omnivorous bird (aquatic)
Green Heron - omnivorous piscivorous bird (aquatic)
Mink - piscivorous mammal (aquatic)
Little Brown Bat - insectivorous mammal (aquatic)
7.2.5 Exposure Point Concentrations
The upper confidence limit (UCL) on the mean (recommended 95 or 99 UCL) was used as an EPC
where possible for. each medium. Samples were pooled across the three areas. ProUCL 4 was used to
calculate UCLs (if two recommended values were given, the higher value was used). If a UCL could not
be calculated because of an insufficient sample size, as for sediment, surface water, and tadpole tissue,
the maximum concentration was used. Sample concentrations from the reference location were not used
to determine EPCs. For terrestrial invertebrates, only field collected invertebrates were used because
these organisms are the most representative of site conditions.
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To assess the potential for adverse effects from mercury exposure, toxicity values were available for
three species of mercury (methyl mercury, mercuric chloride, mercuric sulfide). For the risk assessment,
mercury 2+, Fraction 1, and Fraction 2 were treated as mercuric chloride. Fraction 5 was treated as
mercuric sulfide. In most cases, the sum of the individual mercury species was less than the total
mercury measured in the same sample. This mercury not accounted for (MNAF) was added to the
mercuric chloride measurement when developing EPCs for food web modeling as a conservative
measure. The MNAF was not treated as methylmercury since this constituent was measured directly in
all media. The exception to the treatment of MNAF involved drinking water. For this media, total
mercury detected was assumed to be mercuric sulfide for the purposes of modeling.
Mercury and zinc in aquatic plants, aquatic invertebrates, and small mammals were not measured
directly and had to be estimated for food web exposure. For aquatic plants, sediment concentrations and
the relationships among chemicals measured in soil and terrestrial plant tissue were used to develop site-
specific bioaccumulation factors (BAFs), which were used to estimate aquatic plant EPCs. The BAF
approach was also used for aquatic invertebrates. For small mammals, the BAF from Step 3b was
applied to the total mercury concentration in soil. Methyl mercury and mercuric chloride were assumed
to each represent 50% of the estimated total mercury tissue concentration.
7.2.6 Exposure Assumptions
Literature values for body weight and ingestion rates were available for most of the proposed receptors.
Regression models were used to estimate receptor-specific ingestion rates and tissue concentrations.
Parameters identified for each feeding guild included food and water ingestion rates, components of diet,
incidental soil and sediment ingestion rates, and home ranges. Reference toxicity values were identified
for both NOAELs and LOAELs. Assumptions and toxicity parameters have been reviewed and
approved by FPA Region 4 risk assessors.
7.2.7 Risk Characterization - Direct Exposure
7.2.7.1 Soil Invertebrate Community
The potential for adverse effects to the soil invertebrate community was evaluated through a multi-
parameter weight-of-evidence approach. The parameters considered using this approach were the result
of a comparison of COPEC concentrations in soil to literature-based ecological screening values (ESVs),
the 28-day bioassay results using E. fetida and the results of a qualitative survey of the soil invertebrate
community at each sample location.
Only inorganic mercury exceeded the ES V with high exceedances (HQs greater than 10) in each of three
areas. Methyl mercury did not exceed ESVs.
Toxicity tests using E. fetida were performed with nine soil samples from areas of elevated mercury
concentrations in comparison to other areas of the site (TERA-1, TERA-3, TERA-5, UNP-1, LNP-3,
UNP-5, WB-2, WB-4 and WB-5). A reference sample (SOREF-1) was also collected and a laboratory
control also included in the toxicity testing. Although inorganic mercury concentrations in site toxicity
test using E. fetida exceeded the ESV, negative effects were not observed in site samples when
compared to the reference area. Since consistent performance was observed across site samples, the
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differences from the laboratory control were attributed to a less variable physical characteristic of the
soils such as TOC.
The results of the community survey indicated that lower numbers of organisms or classes of organisms
were not associated with high levels of mercury, except at UNP-3. Sample location UNP-3 had the
highest concentration of inorganic mercury of the sites surveyed and one of the lowest number of total
organisms compared to other survey locations. Sample location UNP-3 also tended to be drier and
contained fill material, resulting in poor soil quality which may have contributed to the low number of
organisms observed.
Risks to the survival, growth, and reproduction of soil invertebrate community were considered to be
within protective levels because differences from the reference area were not observed and there was no
trend in toxicity test response, survey results, or concentrations of constituents in soil.
7.2.7.2 Aquatic Community (Fish and Reptiles)
The potential for adverse effects to the fish and reptile community was evaluated using a similar weight-
of-evidence approach with two parameters: a comparison of mercury concentrations in surface water to
literature-based ESVs and 30-day bioassay results using R. clamitans.
Comparison of surface water data to mercury ESVs indicate mercury concentrations were above the
Region 4 ESV but below the National Recommended Water Quality Criteria (NRWQC) and the total
mercury criterion continuous concentration (CCC) of 0.77 |ug/L for amphibians.
Toxicity tests using R. clamitans were performed with site surface water and sediment from three
locations with sediment mercury concentrations that were elevated in comparison to other areas of the
site (WSED-40, WSED-41, and WSED-42). A reference sample (SEDREF-1) was also collected and a
laboratory control also included in the toxicity testing. Of the three site samples, only WSED-42 had
significantly greater frequency of mortality compared to the laboratory control and reference. No-
significant differences were observed in the mean malformation and wet weight of site samples and the
control and reference samples. However, the three site samples had significantly less mean length
compared to the control, and WSED-40 and WSED-42 showed significantly lower mean length
measurements than the reference.
The results of the toxicity testing indicated that WSED-42 had the highest mortality (51 percent) and
lowest growth (1.6 cm organism and 47 mg organism) and was associated with the highest concentration
of total mercury in sediment. Based on significant differences from the reference location, sediment
mortality lowest observed effect concentration (LOEC) of 0.75 mg/kg and growth LOEC (based on
length) of 0.63 mg kg were identified for mercury. Sediment mercury concentrations at WSED-41 were
below the identified LOECs for mortality and growth. Mercury concentrations of 0.75 mg/kg (Method
7471) and 0.635 mg/kg (Method E1631) were observed at WSED-42 which meet the LOEC for
mortality but are below the LOEC for growth. Surface water toxicity values could not be determined
from results because total mercury was not detected in WSED-42.
To identify other potential causes of toxicity, a sample-by-sample comparison of concentrations in the
toxicity test samples for constituents other than mercury was performed for surface water and sediment.
Other possible surface water contributors to observed effects on tadpoles in the toxicity tests were
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identified as barium and Aroclor 1268 in surface water. However, further evaluation of these two
compounds concluded that barium and Aroclor 1268 were unlikely contributors to observed effects in
the bioassays. Barium compounds were considered to have a low toxicity to aquatic organisms because
the form (barium sulfate) likely present is essentially non-toxic. In a literature review, ENSR (2004)
reported 7- or 10-day lethal Aroclor concentrations with 50 percent mortality (LC50s) for amphibian
early life stages ranging from 1,030 ng/L to 28,000 |ig/L. Sample concentrations in the site toxicity tests
were much lower, ranging from 0.14 to 2.3 ng/L. Considering that the highest concentrations of PCBs in
surface water were also observed at SW-40, which had the lowest effects among the site samples,
surface water toxicity was determined to be an unlikely contributor to observed effects in the bioassays.
In sediment, mercury concentrations from all three sample locations exceeded the lower effects level
(LEL), but not the upper effects level (UEL). Other possible sediment contributors to observed effects in
the amphibian toxicity tests were identified as manganese, benzo(a)pyrene, and indeno(l,2,3-cd)pyrene
in sediment. Further evaluation of these constituents showed that sediment concentrations of manganese,
benzo(a)pyrene, and indeno(l,2,3-cd)pyrene at WSED-40 and WSED-41 were either not detected or
detected below ESVs, though significant negative effects were also observed at these locations. As a
result, the contribution to toxicity by these constituents has been determined to be limited.
Amphibian growth was reduced compared to the reference, but the reduction was only approximately
15% of the reference condition. This difference is unlikely to have community-level effects, which is the
endpoint being evaluated. Risks to the survival, growth, and reproduction of fish and reptile community
are considered to be within protective levels because mortality differences from the reference area were
observed at only one location, only marginal differences in growth were observed, the actual level of
exposure is expected to be low because of the poor quality habitat for fish and reptiles in the drainage
pathways, and attribution to total mercury is unclear.
7.2.7.3 Benthic Invertebrates
The potential for adverse effects to the benthic invertebrate community was evaluated using a multi-
parameter weight-of-evidence approach. The parameters considered in this approach were the results of
a comparison of COPEC concentrations in sediment to literature-based ESVs, 28-day bioassay results
using H. Azteca, and the results of a qualitative survey of the aquatic invertebrate community. Mercury
exceeded the LEL, but not the UEL, in all site samples when compared to literature-based ESVs.
The results of the H. azteca toxicity testing showed mortality and weight were not significantly different
between site and control or reference samples. Other possible contributors to observed effects include
manganese, benzo(a)pyrene, and indeno(l,2,3-cd)pyrene in sediment. While these constituents may
contribute to toxicity at WSED-42, where the highest effects were observed concentrations were either
not detected or were detected below ESVs at the other two locations where significant negative effects
were also observed. As a result, the contribution to toxicity was determined to be limited, abundance and
diversity information gathered from the aquatic invertebrate community survey appeared to be unrelated
to levels of mercury. There is some uncertainty that the survey size and area sampled at each location
were limited.
Since growth differences from the reference area were observed at only one location and the difference
was marginal, risks to the survival, growth, and reproduction of the benthic invertebrates were
considered to be within protective levels.
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7.2.8 Food Web Exposure - Terrestrial
7.2.8.1 Insectivorous Terrestrial Birds - Carolina Wren
Potential risks to the survival, growth, and reproduction of insectivorous bird populations were
evaluated with the Carolina wren as the representative receptor. Exposure doses exceeded Toxicity
Reference Values (TRVs) for methyl mercury (NOAEL-based HQ of 1.6 and LOAEL-based HQ of 0.9),
mercuric chloride (NOAEL-based HQ of 2.1 and LOAEL-based HQ of 1.0), mercuric sulfide (NOAEL-
based HQ of 3.0 and LOAEL-based HQ of 1.5), and zinc (NOAEL-based HQ of 16 and LOAEL-based
HQ of 1.8) because of concentrations in terrestrial invertebrates and incidental soil ingestion. NOAEL-
based and LOAEL-based HQs for the wren were also greater than 1.0 indicating the potential for
adverse effects to this receptor. Invertebrates comprised the majority of the exposure doses for methyl
mercury, mercuric chloride, and zinc, and incidental soil ingestion comprised the majority of the
exposure dose for mercuric sulfide.
7.2.8.2 Insectivorous Mammal - Short-tailed Shrew
Potential risks to the survival, growth, and reproduction of insectivorous mammal populations were
evaluated with the short-tailed shrew as the representative receptor. Exposure doses exceeded TRVs for
mercuric chloride (LOAEL-based HQ of 1.4) and zinc (NOAEL-based HQ of 3.7 and LOAEL-based
HQ of 1.3). NOAEL-based and LOAEL-based HQs for the shrew were also greater than 1.0 indicating
the potential for adverse effects for this receptor group. Terrestrial invertebrates comprised nearly 100%
of the exposure doses for mercuric chloride and zinc. Incidental soil ingestion was included in the
exposure calculation.
7.2.8.3 Herbivorous Birds - Purple Finch
Potential risks to the survival, growth, and reproduction of herbivorous bird populations were evaluated
with the purple finch as the representative receptor. Exposure doses exceeded TRVs for mercuric
chloride (NOAEL-based HQ of 1.7: the LOAEL was not exceeded) and zinc (NOAEL-based HQ of 31
and LOAEL-based HQ of 3.5). NOAEL-based and LOAEL-based HQs for the finch were also greater
than 1.0. Terrestrial plants comprised nearly 100% of the exposure doses for mercuric chloride and zinc.
7.2.8.4 Herbivorous Mammals - Meadow Vole
Potential risks to the survival growth, and reproduction of herbivorous mammal populations were
evaluated with the meadow vole as the representative receptor. Exposure doses exceeded TRVs for
mercuric chloride (LOAEL-based HQ of 1.2) and zinc (NOAEL-based HQ of 6.8 and LOAEL-based
HQ of 2.4. The LOAEL-based HI for mercury was also greater than 1.0. Terrestrial plants comprised
nearly 100% of the exposure doses for mercuric chloride and zinc.
Even though His for terrestrial receptors were generally greater than 1, the identified risks to terrestrial
receptors were concluded as being unlikely to have population level effects, the endpoint being
evaluated. Factors for this conclusion were that the magnitudes of TRV exceedances are low, the sample
locations with elevated concentrations are few and represent only a small percent of the total area, and
the analysis included three conservative features: the inclusion of a full soil ingestion factor for species
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consuming soil invertebrates, the exclusion of Area Use Factor (AUFs), and the use of the UCL as an
EPC. Furthermore, the elevated concentrations of zinc in plants were described as possibly due to a
natural occurrence. Risks to the survival, growth, and reproduction of terrestrial avian and mammalian
species populations were considered low.
7.2.9 Food Web Exposure - Aquatic
7.2.9.1 Amphibians and Reptiles - Bullfrog and Northern Water Snake
Potential risks to the survival, growth, and reproduction of amphibian and reptile populations were
evaluated with the bullfrog and northern water snake as the representative receptors. Except for the
exposure of northern water snake to methyl mercury, exposure doses did not exceed TRVs. However,
methyl mercury was estimated as 50% of the total mercury concentration in vertebrate prey. In general,
methyl mercury content varies greatly among vertebrate species and within specific tissues (hair and
brain tissue typically have the highest content, while liver and kidney content are lower as a result of
demethylation). Risks to the survival, growth, and reproduction of northern water snake populations
were listed as low because the approach used to estimate 50% methyl mercury content was determined
to likely overestimate the actual methyl mercury content, and. because the magnitude of the TRV
exceedance is small.
Based on these results, risks to the survival, growth, and reproduction of amphibians and reptile
populations was considered low.
7.2.9.2 Omnivorous Birds - Wood Duck
Potential risks to the survival, growth, and reproduction of omnivorous bird populations were evaluated
with the wood duck as the representative receptor. Since mercury and zinc exposure doses did not
exceed TRVs risks to the survival, growth, and reproduction of omnivorous bird populations were
considered low.
7.2.9.3 Omnivorous/Piscivorous Birds - Green Heron
Potential risks to the survival, growth, and reproduction of omnivorous piscivorous bird populations
were evaluated with the green heron as the representative receptor. Since mercury and zinc exposure
doses did not exceed TRVs. and only the NOAEL-based HI was greater than 1.0, risks to the survival,
growth, and reproduction of omnivorous piscivorous bird populations were considered low.
7.2.9.4 Insectivorous & Piscivorous Mammals - Little Brown Bat and Mink
Potential risks to the survival, growth, and reproduction of insectivorous piscivorous mammal
populations were evaluated with the little brown bat and mink as the representative receptors. Since
mercury and zinc exposure doses did not exceed TRVs, risks to the survival, growth, and reproduction
of insectivorous piscivorous mammal populations were considered low.
Except for mercuric sulfide and the northern water snake, no risks were identified for the survival,
growth, and reproduction of aquatic avian and mammalian species populations. For water snakes
exposed to methyl mercury, the identified risks were described as unlikely to have population level
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effects (the endpoint being evaluated) since the magnitude of the TRV exceedance was low, the sample
locations with elevated concentrations are few and represent only a small percent of the total area, and
the analysis included conservative factors. Risks to the survival, growth, and reproduction of northern
water snake populations were also low.
7.2.10 Other Food Web Exposure Constituents of Interest
Food web exposure COPECs identified in Step 3a were compared to PRGs developed using assumptions
presented in the Step 3b problem formulation. These comparisons were made to identify: (1) whether
other COPECs (e.g. non risk-drivers) exceed PRGs in areas where the risk drivers do not: and (2) data
gaps warranting further investigation. A few of these constituents exceeded NOAEL-based PRGs in one
or more locations but were below the LOAEL-based PRGs. These constituents were not addressed
further. Constituents exceeding LOAEL-based PRGs included mercury, TCDD (2,3,7,8-
tetrachlorodibenzo-p-dioxin) Toxicity Equivalents (TEQs), aldrin, hexachilorobenzene, and chromium.
Step 3b led to the conclusion that collection of additional data for mercury was sufficient to complete
the BERA.
7.2.10.1 Chromium, Aldrin, and Hexachlorobenzene
Risks to the survival, growth, and reproduction of terrestrial avian and mammalian species populations
from chromium, aldrin, and hexachlorobenzene, were considered to be within protective levels due to
the low frequency of exceedance (3%).
7.2.10.2 TCDD TEQs
Calculated NOAEL-based and LOAEL-based HQs did not exceed 1.0 for piscivorous or omnivorous
avian and reptile wildlife represented by the wood duck, green heron, adult bullfrog, and northern water
snake. Risks to the survival, growth, and reproduction of avian piscivorous or omnivorous species
populations from TCDD TEQs were considered to be within protective levels.
For the Carolina wren, NOAEL-based and LOAEL-based HQs exceeded 1.0 when all data was used.
When elevated data from either TERA-5 or both TERA-5 and UNP-1 data were excluded, NOAEL-
based HQs were reduced by an order of magnitude to levels between 1 and 3. LOAEL-based HQs were
below 1.0.
Since the magnitude of exceedances of TRVs was low and there are few sample locations with elevated
concentrations, which represent only a small percentage of the total area, risks to the survival, growth,
and reproduction of reptile species populations were considered to be within protective levels. Risks
from TCDD TEQs could not be ruled out due to an elevated LOAEL -based HQ when all data were
used. Therefore, a soil PRG based on TCDD TEQ risk to the Carolina wren was calculated as part of the
RI. The soil PRG was determined by back calculating the risk equations to a TCDD TEQ concentration
in surface soil (0 to 0.5 foot bgs) that corresponds to an HQ of 1. The NOAEL-based soil PRG for the
Carolina wren is 0.008 ng/kg, and the LOAEL-based soil PRG is 0.08 (ig/kg. It should also be noted that
TERA-5 is also the area of highest total mercury concentrations in soil, and future remediation for total
mercury will likely remove elevated levels of TCDD.
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Risk estimates for mammalian wildlife were calculated for the entire data set and with elevated data
from TERA-5 or both TERA-5 and UNP-1 excluded. Since NOAEL-based or LOAEL-based HQs did
not exceed 1.0 for mammalian herbivorous or omnivorous wildlife represented by the meadow vole or
mink, risks to the survival, growth, and reproduction of mammalian herbivorous or omnivorous species
populations from TCDD TEQs were considered to be within protective levels.
For flying insectivorous mammalian wildlife represented by the little brown bat, risk estimates using all
data resulted in a NOAEL-based HQ for total TEQs of 6.6 and a LOAEL-based HQ of 0.6. These HQs
suggest that population level effects, the endpoint being evaluated, are unlikely. Risks to the survival,
growth and reproduction of flying insectivorous mammalian wildlife species populations from TCDD
TEQs were considered to be within protective levels.
For insectivorous mammalian wildlife represented by the shrew, risk estimates using all data resulted in
a NOAEL-based HQ for total TEQs of 66 and a LOAEL-based HQ of 6. An additional TRV was then
used based on a mink study; the original TRV study was conducted on a rat.
With this additional TRV a range of HQs was established for the shrew using all data and with elevated
data from TERA-5 or both TERA-5 and UNP-1 excluded. Under these scenarios, HQs based on the rat
study ranged from 63 to 14 based on the NOAEL and between 6.6 and 1.4 based on the LOAEL. Under
the same scenarios using the mink TRV NOAEL-based HQs were all below 1.
The identified risks from TCDD TEQs to insectivorous mammalian wildlife represented by the shrew
are unlikely to have population level effects, the endpoint being evaluated. Factors contributed to this
conclusion include the magnitude of exceedances of TRVs was low. TRVs are not exceeded when
additional TRVs are considered, the sample locations with elevated concentrations are few and represent
only a small percent of the total area, and off-site sources of TEQs are present. TERA-5 is also the area
of highest total mercury concentrations in soil and future remediation for total mercury will likely
remove elevated levels of TCDD. Risks to the survival, growth, and reproduction of insectivorous
mammalian wildlife populations were considered to be within protective levels.
7.2.11 Uncertainties
Uncertainties included in the BERA include:
The use of the MNAF in developing EPCs and for assessing toxicity may overestimate or
underestimate risk.
Incidental soil ingestion was included in the total chemical exposure calculations for terrestrial
wildlife that ingest invertebrates, even though invertebrates were not depurated prior to chemical
analyses. Incidental soil ingestion was included in the total chemical exposure calculations as a
conservative assumption, even though some of the soil ingestion would come from invertebrates
collected in the field. As a result of this approach, risks to terrestrial wildlife may be
overestimated.
Tissue concentrations were measured in tadpoles exposed to site sediment and surface water
because in situ organisms were not available. Tissue concentrations based on laboratory
exposure of tadpoles to site sediment and surface water were then used as surrogates for fish
tissue concentrations for piscivorous wildlife. Differences in fish and tadpole bioaccumulation
are not well studied, but are assumed to be minor. Risks to piscivorous wildlife may be under- or
overestimated.
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Mercury and zinc concentrations in aquatic plants, aquatic invertebrates, and small mammals
were not measured directly and had to be estimated using BAFs. Although the strongest
available relationships were used, the use of modeled tissue concentrations and literature-based
BAFs may under- or overestimate risk.
Except for vertebrate prey, the values used in the BERA were based on measured tissue values
(measured directly or by relationships derived from the measured tissue levels) and are
considered more applicable for determining risks in the BERA. In general, methyl mercury
content varies greatly among vertebrate species and within specific tissues. For vertebrate prey,
the BERA used the EPA requested value of 50% based on the total mercury soil UCL (16.7
mg/kg) multiplied by the BAF and 0.5. Therefore, risk from exposure to methyl mercury may be
overestimated.
The recommended UCL from ProUCL 4.0 was used as the EPC, or if a UCL could not be
calculated, the maximum concentration was used as the EPC. For some constituents, the actual
EPC may be closer to the arithmetic average than the UCL. Risks based on UCL and maximum
EPCs may be overestimated if the actual EPC is closer to the arithmetic average.
An adequate avian TRV for mercuric sulfide was not identified and the TRV for mercuric
chloride was used as a surrogate instead. Since mercuric sulfide is considered to be less toxic
than mercuric chloride, risk estimates for birds and mercuric sulfide may be overestimated.
A soil reference sample, location SOREF-1 was collected in the same area that was previously
identified as the reference location for the site during the Phase II sampling in November 2005.
This area showed poor earthworm survival, poor soil quality, and limited numbers or classes of
organisms during the soil community survey. If earthworm survival had been higher in the
reference area, survival in site soils may have been statistically lower.
Uncertainties identified by an EPA ecological risk assessor in reviewing the draft ROD include:
1. Site-specific data was collected for bioaccumulation of mercury into terrestrial invertebrates.
Site-specific data was unavailable for bioaccumulation of Aroclor 1268 into insects. There is
some uncertainty in the cleanup levels in the draft ROD on account of having used literature
assumptions for bioaccumulation in the food-chain models that were used to develop the
cleanup levels for Aroclor 1268. The uncertainty does not affect the selected remedy for the
Wooded Bottomland Area Drainage Pathways. Most of the concentrations of Aroclor 1268
above preliminary remedial goals (PRGs) derived from conservative assumptions are
encompassed in the footprint selected for excavation.
2. The changes to the toxicity reference value (TRV) and the bioaccumulation factors (BAFs)
since the point at which the risk assessment was prepared may indicate uncertainty in the
cleanup goal for protection of ecological receptors from Aroclor 1268 in Wooded
Bottomland Area soils. The concentrations of Aroclor 1268 in Wooded Bottomland Area
soils outside of the remedial footprint are mostly below 3 mg/kg. Soils with concentrations of
Aroclor 1268 substantially above 3 mg/kg are typically located adjacent to the areas that are
planned to be excavated under the selected remedy. It is recommended that any adjustments
to toxicity values or other assumptions in the risk assessments be evaluated during the
remedial design phase. Slight adjustments might be possible to the remedial footprint, but the
overall remedy will remain the same.
3. The food-chain models that were used to derive the CULs in the ROD were checked as part
of this review. The life history parameters were found in Table 3-15 of the baseline
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ecological risk assessment (BERA) CH2MHILL (2010). The TRVs were found in Table 4-13
of the BERA. The ecological CULs from the BERA food-chain models used in the ROD
were:
3 mg/kg for total mercury in Wooded Bottomland Area Soils (HI = 1) for the short-
tailed shrew.
0.0854 fig/kg for 2,3,7,8-TCDD toxicity equivalents in Wooded Bottomland Area
Soils (HQ = 0.9) for the Carolina wren
47 mg/kg for Aroclor 1268 in Wooded Bottomland Area Drainage Pathway
Sediments (HQ = 1) for the green heron.
The transfer factors between abiotic media and concentrations in tissues needed to derive the
PRGs were uptake of mercury from soil into terrestrial invertebrates to support the diet of the
short-tailed shrew. Overall, the CULs were okay. It was difficult to review them because the
information was in the BERA but also in the Step 3b document (CH2MHILL 2009). It would
be advantageous to have a summary of the derivation of CULs in an appendix to the ROD for
ease of reference.
4. A site-specific uptake factor from measurements
of mercury in terrestrial invertebrates was used in
the BERA (Figure 1). The calculation of the PRG
for mercury in soils for the short-tailed shrew is
shown in Appendix B of the BERA.
5. The PRG for 2,3,7,8-TCDD Toxicity Equivalents
for the Carolina wren required an uptake factor
for 2,3,7,8-TCDD from soil to terrestrial plants
and an uptake factor for 2,3,7,8-TCDD from soil
to terrestrial invertebrates. The uptake factor for
2,3,7,8-TCDD for plants came from EPA (2007).
The document presented a formula for estimating
a BAF for uptake from soils to plants for organic
compounds as a function of the octanol-water
partition coefficient in Figure 5 of the guidance document.
Uptake of 2,3,7,8-TCDD toxicity
equivalents in to terrestrial plants:
log BAFpiant = -0.229 x log Kow + 1.0237
BAF = Bioaccumulation Factor
(concentration in plant in mg/kg dry
weight to concentration in soil in
mg/kg dry weight)
Kow = Octanol-water partition
coefficient, L/kg
Log Kow (2,3,7,8-TCDD) = 6.8 L/kg.
BAFtcdd = 0.29 in dry weight units.
Uptake of 2,3,7,8-TCDD into Terrestrial Invertebrates (Sample et
al. 1998)
ln(earthworm)=BO+Bl(ln[soil])
earthworm = concentration in earthworm, mg/kg dry weight
soil = concentration in soil, mg/kg dry weight
B0 = 1.182
Bl=3.533.
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6. The uptake of 2,3,7,8-TCDD toxicity equivalents in to terrestrial invertebrates was an
equation obtained from Sample et al. 1998. The equation is presented in Table 7-2 of
CH2MHILL (2009).
7. The calculation of the PRG for 2,3,7,8-TCDD toxicity equivalents is shown in Appendix C-2
to CH2MHILL (2009). The contribution to exposure to the Carolina wren from ingestion of
plants is the concentration of TCDD in plants (0.0854 ng/kg x 0.29) multiplied by the dietary
fraction of plants (0.06). The outcome (0.0854 |ig/kg x 0.29 x 0.06) will be summed with the
calculated exposure through ingestion of terrestrial invertebrates and incidental ingestion of
soil. The predicted concentration in terrestrial invertebrates for 8.54E-5 mg/kg in soil was
5.3E-04 mg/kg in terrestrial invertebrates. The predicted TCDD concentration in terrestrial
invertebrates is multiplied by the dietary fraction (0.94). The outcome (5.3E-04 x 0.94) will
be summed with the calculated exposure through incidental ingestion of soil. The fraction of
the food ingestion rate that was assumed to be incidental ingestion of soil was 10%. The rate
is multiplied by the concentration of TCDD in soil. Total intake is:
(8.54E-5 mg/kg x 0.29 X 0.06 +
5.3E-04 mg/kg x 0.94 +
8.54E-05 mg/kg * 0.1) x 0.248 / 1.4E-04,
Where 0.248 is the body-weight normalized food ingestion rate of the Carolina wren, and
1.4E-4 mg/kg-day is the Lowest Observable Adverse Effect Level (LOAEL) TRV for
2,3,7,8-TCDD toxicity equivalents. The hazard quotient should be 0.9, which it is.
The green heron (Butorides virescens) was considered to be the most sensitive ecological receptor for
Aroclor 1268 in Wooded Bottomland Area sediments with a CUL of 47 mg/kg. The calculation of the
PRG for Aroclor 1268 in sediments for the green heron was found in CH2MHILL (2009). The green
heron's diet consisted of aquatic invertebrates and forage fish in proportion of 55% aquatic invertebrates
and 45% forage fish. The PRG for Aroclor
1268 in sediments for the green heron
required an uptake factor for uptake of
Aroclor 1268 from sediments to aquatic
invertebrates and an uptake factor for
Aroclor 1268 from sediments into forage
fish. The uptake factors used came from the
EPA comment memo that was attached to
CH2MHILL (2009). The uptake factor from
sediments to aquatic invertebrates used in CH2MHILL (2009) was 0.95, which was an average biota-to-
sediment transfer (BSAF) in units of concentration in tissue normalized to lipid concentration to
concentration in sediment normalized to organic carbon concentration. The comment indicated that the
lipid content in benthic invertebrate tissue can be assumed to be 5%. The organic carbon content in
sediments was indicated to be assumed to be 1%. The BSAF would ideally have been adjusted by the
lipid content in the organism before using it in the food-chain model to calculate the PRG for the green
heron. Since this multiplication was not performed, the previous model in Table 7-2, which came from
Bechtel-Jacobs, 1998, was used for checking.
Uptake of Aroclor 1268 into Aquatic Invertebrates
(Bechtel Jacobs, 1998)
ln(aq. invertebrate)=BO+Bl(ln[sediment])
BO = 1.6
B1 = 0.939.
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7.2.12 Conclusions
The BERA was finalized in 2010 and addressed Steps 1 through 3B of the ERA process. Ecological
resources at the site were identified and evaluated for potential risk from site-related COPECs.
Ecological risk calculations included in the BERA were developed for areas containing viable wildlife
habitat and did not include areas that were intended to be removed as part of the site redesign or planned
remedial activities. Areas with available habitats include the terrestrial areas of the Upland Non-Process
and Wooded Bottomland Areas. Soil, sediment, and surface water samples collected throughout the
Wooded Bottomland Area, Upland Non-Process Area, Streams A and B, and Wetland B were used to
evaluate potential risk in the BERA.
The BERA identified wildlife hazards associated with exposure to mercury and PCBs for the Wooded
Bottomland Area, the Upland Non-Process Area, and Wetland B. The BERA focused on indicator COCs
rather than all detected constituents in site media.
Hazards from mercury in sediment and soil are considered low. The hazards were spatially isolated,
inputs to the risk analysis were conservative, and field observations indicated significant wildlife use. A
PRG of 3 mg/kg for mercury in Wooded Bottomland Area soil was calculated by EPA based on the data
collected for the BERA, and 3 mg/kg was selected as the Wooded Bottomland Area soil PRG for
mercury. Although the BERA did not define a PRG for mercury in sediments, potential sediment
toxicity to amphibians and benthic macroinvertebrates was indicated at a concentration greater than 0.75
mg/kg mercury. The value of 0.75 mg/kg was selected as the PRG for on-site sediments based on the
lowest observed effects concentration in R. clamitans and H. azteca toxicity tests in the BERA.
Sediment PRGs for the COPEC driving most of the unacceptable risk in Bottomland surface sediment
(i.e., Aroclor 1268) was determined by reverse calculation of LOAEL-based ecological risk equations to
an HI equal to 1.0 for each receptor and COPEC evaluated in Step 3B. For Aroclor 1268, the most
sensitive aquatic receptor (i.e., the receptor corresponding to the calculated lowest PRG) was the green
heron. The LOAEL-based sediment PRG for Aroclor 1268 is 47 mg/kg. Aroclor 1268 was not an
ecological COC for surface soil.
Although 2,3,7,8-TCDD TEQ was not listed as a COC in the BERA, a PRG was calculated as part of the
Final FS Report for 2,3,7,8-TCDD TEQ (dioxins/furans) and 2,3,7,8-TCDD (dioxin-like PCBs) in
Wooded Bottomland Area surface soil based on risk to the Carolina wren. The 2,3,7,8-TCDD TEQ
(dioxins/furans) PRG for Bottomland surface soils (0-0.5 feet) is 85.4 ng/kg. The 2,3,7,8-TCDD TEQ
(dioxin-like PCBs) PRG for Bottomland surface soils (0-0.5 feet) is 196 ng/kg.
In the FS, Bottomland sediments were also evaluated in the calculation of potential PRGs protective of
wildlife receptors exposed to 2,3,7,8-TCDD TEQ (dioxins/furans) and 2,3,7,8-TCDD TEQ (dioxin-like
PCBs). Potential risk was identified to the green heron from exposure to Bottomland sediments. The
2,3,7,8-TCDD TEQ (dioxin-like PCBs) PRG for Bottomland Area surface sediment (0-0.5 feet) is 210
ng/kg. The 2,3,7,8-TCDD TEQ (dioxins/furans) PRG for Bottomland Area surface sediment (0-0.5 feet)
is 280 ng/kg.
Overall, available information suggests that the upgradient portion of Stream B may be an isolated area
of concern. Stream A, upgradient of its confluence with Stream B, was previously identified for
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remedial action. Constituent concentrations downgradient of these two areas are expected to decrease
with remediation in either stream.
8.0 REMEDIAL ACTION OBJECTIVES
The Remedial Action Objectives (RAOs) for the site are:
Upland Process and Non-Process Areas
Reduce risk to construction/industrial workers from exposure through dermal adsorption and
incidental ingestion from surface and subsurface soils containing mercury and Aroclor 1268 by
reducing concentrations to levels that are protective for commercial and industrial uses.
Prevent migration of mercury and Aroclor 1268 from upland surface soils and the solids in the
storm water conveyance system to the Wooded Bottomland Area by reducing concentrations to
levels that are protective of human and ecological receptors.
Reduce risks to construction/industrial workers from and prevent migration of principal threat
wastes by treating/solidifying the mercury waste and contaminated soils beneath the former
Mercury Cell Building and Retort pads.
Wooded Bottomland Areas
Reduce risk to adolescent trespassers from exposure through dermal adsorption of surface water
containing Aroclor 1268 by reducing concentrations to protective levels.
Reduce risk to adolescent trespassers from exposure through dermal absorption and incidental
ingestion of surface soil containing Aroclor 1268 by reducing concentrations to protective levels.
Reduce risk to ecological receptors from sediment contaminated with mercury and Aroclor 1268
by reducing concentrations to protective levels.
Reduce risk to ecological receptors from surface soil contaminated with mercury by reducing
concentrations to protective levels.
The completed remedy will reduce risks to human and ecological receptors to levels provided for in the
NCP (i.e. excess cancer risk equal to or less than 10"5, and excess non-cancer risk equal to or less than
HI of 1). The selected remedy will lower the risks by reducing the concentrations of the soil, sediment
and surface water contaminants to the cleanup levels in Section 12.4 (Table 104 and Table 105).
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9.0 DESCRIPTION OF ALTERNATIVES
The site remedial alternatives are grouped into two categories within the site, Overall Site (Alternatives
A-l through A-6) and mercury waste and soil contamination considered PTW which is located in the
Retort Area and Mercury Cell Building Pads (Alternatives S-l through S-4). This grouping simplified
the alternative development and evaluation due to the different conditions within each category. The
evaluation and selection of the remedial alternative for mercury waste and contaminated soils associated
with the Retort Area and Cell Building pads (S-l through S-4) is independent of the remedial alternative
selection for the remainder of the site. Implementation of the remedies under each category may be
conducted concurrently where this would result in potential cost savings and efficiencies through reuse
of common remedial components such as labor, equipment, access roads, and staging areas. Sequencing
of remedial alternatives will be considered during remedial design. The final remedy selected for the site
will include one alternative from the A-group and one alternative from the S-group. Table 87 lists the ten
alternatives designation and title.
Table 87: List of Remedial Alternatives
Area
FS
Designation
Title
Overall Site
A-l
No Action
A-2
Capping with Limited Excavation, Off-site Disposal or On-site Treatment,
and Institutional Controls (ICs)/Engineering Controls (ECs)
A-3
Combination of Capping and Excavation, On-site Disposal, and ICs/ECs
A-4
Combination of Capping and Excavation, Off-site Disposal, and ICs/ECs
A-5
Excavation, On-site Disposal, and ICs/ECs
A-6
Excavation, Off-site Disposal, and ICs/ECs
Retort and
Cell
Building
Pad Areas
S-l
No Action
S-2
Capping with Vertical Impermeable Barrier Installation and ICs
S-3
Treatment with In-Situ Stabilization/Solidification, Capping and ICs
S-4
Excavation and Off-site Treatment and Disposal
9.1 Description of Remedy Components
Descriptions of each of the ten alternatives follow in Sections 9.1.1 through 9.1.10. Table 88 lists each
remedial area. The former RCRA surface impoundments that are closed are part of the site and will be
included in the selected remedy although no separate remedial alternatives were developed and
evaluated.
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Table 88: Remedial Area Description
Remedial
Area
Assoclated AOIs*
Area Description
A
WCBPA & NCBPA
Area West of CBP
B
WWTP
Soutwest Comer of WWTP
C
OSD, RYD & RP
Membrane Plant Ancilliary Areas
D
FIL
Fill Area
E
NCBPA, OPA & RYD
Areas Northeast of Cell Building Pad
F
RET
Retort Area
G
CBP
Cell Building Pad
H
WWTS
Wastewater Treatment Solids
I
SCS
Stormwater Conveyance System
J
Drainage Pathways
Wooded Bottomland Areas (Including Drainage Pathways)
K
WBA (North)
Wooded Bottomland Area (North of Fill Area)
L
ONP & NRB
Areas Northeast Corner of ONP and Southeast Corner of NRB
M
WBA (North)
Wooded Bottomland Area (North of Fill Area)
Notes:
AOIs* - The Areas of Interest noted are remedial areas that were selected for remedial action and subsequent technology
screening. Some AOIs were excluded from remedial action as the RI results in these areas did not exceed PRGs. These
remedial areas may only include a portion of the AOI or all of the AO I, which was dependent on the RI results, PRGs,
regulatory requirements and alternative technologies selected. A complete list of all AOIs evaluated are discussed in Table 1-
4 of the FS.
Acronyms:
CBP -
Cell Building Pad
FIL
Fill Area
NCBPA
North Cell Building Pad Area
WCBPA
West Cell Building Pad Area
NRB -
North Retention Basin
ONP -
Old North Pond
OPA
Old Parking Area
OSD
Old Salt Dock
RET
Retort Area
RP
Robert's Pond
RYD
Rail Y ard
SCS
Starmwater Conveyance System
SWDS-
Solid Waste Disposal Site
WBA
Wooded Bottomland Area
WWTS -
Wastewater Treatment Solids
WWTP-
Wastew ater Treatment Plant
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9.1.1 Alternative A-1: No Action
Estimated Costs:
Capital Cost
$0
Annual O&M Cost
$0
Total Cost
$0
Total Present Worth Cost
$0
Estimated Timeframes:
Construction Timeframe
0 months
Time to Achieve RAOs
beyond our lifetime
No Action includes no new remedial measures or ICs. According to the NCP (40 CFR § 300.430(e)(6)),
No Action is retained for detailed analysis and used as a baseline in comparing alternatives. The No
Action alternative assumes that current security monitoring and restrictions on trespassing would not be
enforced, no additional monitoring would be conducted, and operation of the existing stormwater
treatment system would be discontinued.
9.1.2 Alternative A-2: Capping with Limited Excavation, Off-site Disposal, and ICs/ECs
Estimated Costs
A-2a
(off-site disposal
of WWTS)
A-2b
(on-site treatment
of WWTS)
Capital Cost
$ 18,647,700
$ 20,180,300
Annual O&M Cost
$ 31,500
$ 31,500
Total Cost
$ 19,700,000
$ 21,300,000
Total Present Worth Cost
$ 19,000,000
$ 20,600,000
Estimated Timeframes
Construction Timeframe
12 months
12 months
Time to Achieve RAOs
12 months
12 months
This alternative includes:
Capping of most of the UPA
Excavation of the Wooded Bottomland Area drainage ditches, low-lying portions of the Wooded
Bottomland Area, and other isolated areas to approximately 2 feet with disposal of excavated
material in an off-site EPA-approved TSCA chemical waste landfill
Closure of the stormwater conveyance system
Decommissioning of the stormwater treatment system and restoration of the site to natural
drainage following completion of remedial action
ICs/ECs
Either transporting and disposing the WWTS off-site or treating the solids by low temperature
thermal destruction (LTTD) so that the treated residuals can be beneficially reused as fill on the
site
Capping/erosion control would be implemented in the L Areas along the berm of the Upland
Non-Process Area
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Figure 38 illustrates remedial actions for Areas A through M (minus F and G).
Figure 38: Alternative A-2 Conceptual Remedial Plan
The rationale for selecting areas to be capped or removed is based on the size/local extent of detected
contamination, the magnitude of PCB and mercury concentrations, and the location/exposure risk.
Remedial activities in the UPA include mostly capping with excavation of isolated areas with mercury
or PCB concentrations that exceed cleanup levels protective of the industrial or construction worker in
accordance with the RAOs.
Capping and excavation in the UPA would also serve to protect the Wooded Bottomland Area by
preventing contact of UPA soil with surface runoff and the potential migration of soil into the Wooded
Bottomland Area. Areas in the UPA to be capped under Alternative A-2 include Areas A, C, and D.
Several isolated areas (B, E, K, and M) with concentrations greater than the cleanup levels would be
excavated because long-term maintenance of a small cap in each of these areas would not be practical.
Similarly, the remedial areas in the Wooded Bottomlands Area (J Areas) would also be excavated to
limit long-term maintenance. Excavated areas would be backfilled to approximately original grade and
revegetated under this alternative. Capping and erosion control would occur in the L Areas, which are
located along the steep portion of the Upland Non-Process Area berm. Removal of L Areas is not
recommended due to the potential for destabilizing the berm during remedial action.
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Capping
In Alternative A-2, a cap would be applied over the larger contiguous UPA that exceed the Aroclor 1254
and Aroclor 1268 surface and subsurface soil cleanup level of 11 mg/kg (Areas A, C, and D) and the L
Areas along the berm of the Upland Non-Process Area impoundments. The anticipated extent of capping
for this scenario is shown on Figure 38. The total cap area for this alternative is estimated to be
approximately 2.4 acres. The final cap footprint would be confirmed during remedial design sampling.
Capping includes placing a membrane-soil cap system with a vegetated cover over the remediation area.
The cap design must meet the North Carolina substantive requirements for a final cover on a RCRA
Subtitle D solid waste landfill as well as post-closure requirements that are determined by EPA to be
"relevant and appropriate" and identified as ARARs. Before cap placement, the area would be prepared
by clearing vegetation and leveling in-ground structures. A protective soil layer and geotextile
membrane would be placed over the area to isolate the PCB-containing soil. Another layer of protective
soil would be placed on top of the membrane, plus a layer of topsoil that would be vegetated for final
restoration and erosion control.
Material specifications would require fill soil to be clean. The cap composition assumed for costing is a
protective underlayment of fill soil (compacted in place), a geosynthetic liner, a protective layer of fill
soil on top of the liner soil, plus up to six inches of topsoil to support revegetation. The actual cap
composition and soil layer thicknesses would be evaluated during the remedial design and will comply
with capping ARARs.
Cap placement activities would be conducted using standard construction equipment (e.g., backhoes,
bulldozers, graders, etc.). Topographic survey and GPS instrumentation would be used to confirm
extents and final grades of cap emplacement.
Excavation
Alternative A-2 consists of excavating isolated Upland Process Areas B and E and Wooded Bottomland
Areas J, K, and M. Areas B and E exceed the UPA Aroclor 1254+Aroclor 1268 surface and subsurface
soil cleanup level (11 mg/kg). Areas J exceed the Wooded Bottomland Area Aroclor 1268 sediment
cleanup level (47 mg/kg) and the mercury sediment cleanup level (0.75 mg/kg). Areas K and M exceed
the Wooded Bottomland Area Aroclor 1254+Aroclor 1268 surface soil cleanup level (21 mg/kg). The
anticipated extent of excavation for this scenario is shown on Figure 38. The total in-place excavation
volume is estimated to be 10,900 yd3. The actual excavation footprints of the isolated areas would be
confirmed during remedial design sampling. Following excavation, clean backfill/topsoil would be
placed in the areas to restore the ground surface to approximately pre-excavation grades and the areas
seeded/revegetated to control erosion.
Removal activities would be conducted using standard construction equipment (e.g., backhoes,
bulldozers) equipped with GPS instrumentation to monitor removal progress and confirm that
excavations meet the established horizontal and vertical goals. Backfill would be placed to
predetermined elevations using conventional earthmoving equipment. Seeding and erosion controls
would be implemented upon verification that backfill design elevations have been met.
Where required, excavated soil would be stockpiled within a materials staging area for dewatering to
meet appropriate disposal requirements before transportation. Drying would be accomplished through a
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combination of gravity dewatering and/or the addition of amendments (e.g., bed ash, fly ash, or portland
cement). Drainage from dewatering operations and potentially impacted stormwater would be managed
through the existing stormwater conveyance and treatment system. Excavated and dewatered materials
would be transported for disposal to an appropriate EPA-approved off-site permitted RCRA solid waste
or hazardous waste landfill or TSCA chemical waste landfill.
Stormwater Conveyance
The stormwater conveyance system (I Areas) would be closed by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout. Solids, if removed during closure of the
system, would be dewatered and disposed in an appropriate off-site EPA-approved landfill.
Following completion of site-wide remedial activities active stormwater collection and management
would no longer be necessary. Therefore, the existing stormwater treatment system would be
decommissioned and the site returned to natural drainage. Long-term maintenance would include
inspection and repair of erosion controls designed to mitigate sedimentation during stormwater flow
events.
WWTS (Areas H) containing PCB concentration greater than 50 mg/kg are temporarily stockpiled at the
Mercury Cell Building pad and the SWDS. Alternative A-2 consists of either off-site disposal of the
WWTS at an EPA-approved TSCA chemical waste landfill or treatment of PCBs through LTTD so that
the residue can be beneficially reused as fill on-site where possible. The total volume of the stockpiled
soil on both the Mercury Cell Building pad and the SWDS is approximately 23,700 yd3.
LLTD ex-situ treatment would employ the application of heat and reduced pressure to volatilize and
desorb PCBs from soil. The stockpiled soil would be dried, screened, and then placed in a thermal
desorber, such as a rotary kiln or auger system, and heated to volatilize and transfer PCBs to a gas
stream. The off-gas stream would be passed through wet scrubbers or fabric filters to remove particulate
matter. PCBs would typically be removed through condensation followed by carbon adsorption, or
destroyed in a secondary combustion chamber or a catalytic oxidizer.
Ancillary Activities
Site preparation would include the construction of access roads, support zones, and staging areas for
personnel, equipment, and material. Clearing and installation of erosion controls would be required for
support and staging areas.
Ancillary activities to support construction activities would include: cap/excavation area access and
preparation, erosion control, backfill material delivery and staging, excavated material staging and
handling, cover soil delivery and staging, construction waste disposal, cap placement verification, waste
soil transport and disposal, stormwater management, dust monitoring/control, seeding/planting, and
restoration, as needed.
Ambient air would be monitored for dust during construction. Dust control measures would be
implemented, and would include wetting roads, stockpiles, and staging areas. Real-time air monitoring
would be performed during construction activities to verify compliance with ARARs.12
WWTS
12 The list of ARARs for the remedy alternatives is in Section 9.2, beginning on page 212.
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Site-wide long-term maintenance and inspection would be required to evaluate backfill erosion and to
verify cap and previously-closed RCRA unit performance over time. Long-term monitoring of
groundwater would also be required to confirm closed unit integrity and compliance with ARARs.
Periodic maintenance would be carried out as needed to preserve or restore the integrity of these
systems. ICs and ECs would be employed to prevent unacceptable exposure to humans. ICs would
consist of land use restrictions included in a deed notice and/or environmental restrictive covenant that is
drafted in accordance with North Carolina statutory requirements and recorded in the County. ECs
would consist of warning signs and fencing. The site is currently fenced along the west, south, and east
property boundaries.
9.1.3 Alternative A-3: Combination of Capping and Excavation, On-site Disposal and ICs/ECs
Figure 39 illustrates remedial actions for areas A through M (minus F and G). The rationale for selecting
areas to be capped or excavated is based on the size/local extent of detected contamination, the
magnitude of PCB and mercury concentrations, and the location/exposure risk.
Figure 39: Alternatives A-3 and A-4 Conceptual Remedial Plan
JOB: 6550-12-0S39
REMEDIAL ALTERNATIVES M AND ** - C*
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Summary of Remedial Alternative Selection
September 2017
Estimated Costs:
Capital Cost
$12,122,700
Annual O&M Cost
$36,500
Total Cost
$13,300,000
Total Present Worth Cost
$12,600,000
Estimated Timeframes:
Construction Timeframe
18-24 months
Time to Achieve RAOs
18-24 months
This alternative includes:
Excavation of approximately 15,400 yd3 of contaminated soil and sediment
Capping approximately 1.7 acres of contaminated soil with a geosynthetic liner and vegetative
cover
Construction, operation, closure, maintenance and monitoring of an on-site disposal unit that
meets TSCA chemical waste landfill ARARs in 40 CFR § 761.75
Closure of the underground storm water conveyance system by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout
Disposal of stockpiled WWTS, solids removed from the storm water conveyance system, and
excavated contaminated soil and sediment that are not RCRA hazardous wastes in the
constructed on-site TSCA disposal unit
Treatment and/or disposal of RCRA hazardous wastes including soil that is considered RCRA
characteristic waste or contains RCRA listed waste, if generated, at an off-site permitted RCRA
treatment/disposal facility
Decommissioning of the storm water treatment system and restoration of the site to natural
drainage following completion of remedial action
Disposal or recycling of demolition debris from the stormwater treatment system and other
potentially dismantled structures. Disposition will be determined based on testing of the debris to
determine if it is RCRA hazardous wastes.
Monitoring and maintenance of the closed RCRA units (former surface impoundments) in
accordance with RCRA ARARs for post-closure care of a hazardous waste surface impoundment
Groundwater monitoring in accordance with ARARs to confirm TSCA disposal unit and closed
RCRA units' integrity
ECs in the form of fencing, warning signs and erosion control measures to control sedimentation
from stormwater runoff
ICs in the form of a restrictive covenant and/or Notice of Contaminated Site in accordance with
North Carolina statute
FYRs
Remedial activities in the UPA include capping and excavation of soil areas with mercury or PCB
concentrations that exceed cleanup levels protective of the industrial or construction worker in
accordance with the RAOs. Capping and excavation in the UPA would also serve to protect the Wooded
Bottomland Area by preventing contact of UPA soil with surface runoff and the potential migration of
soil into the Wooded Bottomland Area.
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Summary of Remedial Alternative Selection
September 2017
Table 88 on page 161 describes each remedial area. Areas in the UPA to be capped include Areas A and
C. Areas A and C have detected concentrations of PCBs greater than 25 mg/kg but less than 50 mg/kg.
Area D contains concentrations of PCBs greater than 50 mg/kg, and would be excavated under this
alternative. Several isolated areas (B, E, K, and M) with concentrations greater than the cleanup levels
would be excavated because long-term maintenance of a small cap in each of these areas would not be
practical.
Similarly, the remedial areas in the Wooded Bottomlands Area (J Areas) would be excavated to limit
long-term maintenance. Excavated areas would be backfilled to approximately original grade and
revegetated under this alternative. Capping and erosion control would occur in the L Areas, which are
located along the steep portion of the Upland Non-Process Area berm. Removal of L Areas is not
recommended due to the potential for destabilizing the berm during remedial action.
Capping
In Alternative A-3, a cap would be applied over the larger contiguous Upland Process Areas that exceed
the Aroclor 1254+Aroclor 1268 surface and subsurface soil cleanup level of 11 mg/kg in Areas A and C
and the L Areas along the berm of the Upland Non-Process Area impoundments. The anticipated extent
of capping for this scenario is shown on Figure 39. The total cap area for this alternative is estimated
to be approximately 1.7 acres. The final cap area footprint in some areas would be confirmed during
remedial design sampling.
Capping would be achieved by the same methods described for Alternative A-2. The cap composition
assumed for costing is a protective underlayment of fill soil (compacted in place), a geosynthetic liner, a
protective layer of fill soil on top of the liner soil, plus up to six inches of topsoil to support revegetation.
The actual cap composition and soil layer thicknesses would be evaluated during the remedial
design. Cap placement activities would be conducted using standard construction equipment (e.g.,
backhoes, bulldozers, graders, etc.). Topographic survey and GPS instrumentation would be used to
confirm extents and final grades of cap emplacement.
The caps will be designed to meet site-specific ARARs which include the North Carolina RCRA
Subtitle D landfill final cover as well as post-closure requirements that are relevant and appropriate.
Excavation
Alternative A-3 consists of excavating soil contamination in the Upland Process Areas B, D, and E and
Wooded Bottomland Areas J, K, and M. Areas B, D, and E exceed the Upland Process Area Aroclor
1254+Aroclor 1268 surface and subsurface soil cleanup level (11 mg/kg) protective of human health.
Areas J exceed the Wooded Bottomland Area Aroclor 1268 sediment cleanup level (47 mg/kg) and the
mercury sediment cleanup level (0.75 mg/kg) protective of ecological receptors. Areas K and M exceed
the Wooded Bottomland Area Aroclor 1254+Aroclor 1268 surface soil cleanup level (21 mg/kg)
protective of an adolescent trespasser/recreators.
The anticipated extent of excavation for this scenario is shown on Figure 39. The total in-place
excavation volume is estimated to be 15,400 yd3. The actual excavation footprints of the isolated areas
would be confirmed during remedial design sampling. Following excavation, clean backfill/topsoil
would be placed in the areas to restore the ground surface to approximately pre-excavation grades and
the areas would be seeded/re-vegetated to control erosion.
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September 2017
Removal activities would be conducted as described for Alternative A-2.
Stormwater Conveyance System
The stormwater conveyance system (I Areas) would be closed by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout. Solids, if removed during closure of the
system, would be dewatered and disposed either (1) in the on-site TSCA disposal unit, or (2) at an EPA-
approved off-site landfill if determined to be a RCRA hazardous waste.
Following completion of site-wide remedial activities active stormwater collection and management
would no longer be necessary. Therefore, the existing stormwater treatment system would be
decommissioned and the site returned to natural drainage. Long-term maintenance would include
inspection and repair of erosion controls designed to mitigate sedimentation during stormwater flow
events.
WWTS
WWTS (Areas H) containing PCB concentration greater than 50 mg/kg are temporarily stockpiled at the
Mercury Cell Building pad and the SWDS. Alternative A-3 includes disposal of the WWTS in an on-site
disposal unit that meets TSCA chemical waste landfill requirements which are identified as ARARs.
The total volume of the stockpiled soil on both the Mercury Cell Building pad and the SWDS is
approximately 23,700 yd3.
On-site TSCA Disposal Unit
Approximately 39,100 yd3 of contaminated soil, sediment, and solids would be disposed of in an on-site
newly constructed TSCA disposal unit. Because some of the contaminated media include PCBs at
concentrations greater than 50 mg/kg, the disposal unit will be designed and constructed to meet the
requirements of a TSCA chemical waste landfill as listed in 40 CFR §761.75 that are identified as
ARARs. RCRA hazardous wastes, if generated during the remedial action, will not be placed in the on-
site TSCA disposal unit. They will be disposed of at an off-site EPA-approved RCRA Subtitle C
landfill.
Waiver and Design
40 CFR § 761.75(b)(3) requires that the bottom of a chemical waste landfill be at least 50 feet above the
historical high groundwater table. This distance is not naturally available at the site because there is
shallow groundwater. The 50 feet depth requirement is the only item in paragraph (b) which cannot be
met at the site. TSCA regulations at 40 CFR 761.75(c)(4) allows the Regional Administrator13 to waive
one or more of the requirements of paragraph (b) if evidence is submitted that indicates that operation of
the landfill will not present an unreasonable risk of injury to health or the environment from PCBs when
one or more of the requirements of paragraph (b) of this section are not met. This "no unreasonable risk
of injury to health or environment" standard is less stringent than the CERCLA Section 121(b) threshold
requirement that the selected remedy be protective of human health and the environment. The CERCLA
protectiveness requirement is addressed as part of the Comparative Analysis of Alternatives in Section
10.1.
13 Approval authority for CERCLA remedies selected in RODs (which includes ARAR determinations and use of a waiver
where justified) has been delegated from the Regional Administrator to the Superfund Division Director.
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Summary of Remedial Alternative Selection
September 2017
To support the approval of a waiver under 40 CFR 761.75(c)(4) and meet the CERCLA threshold
protectiveness requirement, the TSCA disposal unit will be constructed using a dual-liner system. A
summary of the design specifications for a dual liner system includes the following:
The dual liner system would consist of a primary and secondary liners, each constructed with
synthetic membranes embedded between protective soil layers
Each membrane would have a permeability equal to or less than 1 x 10"7 cm/sec, be made of a
material that is chemically compatible with PCBs, and be at least 30 mils thick
Both membranes would be placed upon an adequate soil underlining and with a soil cover to
prevent excessive stress or rupture
Between the liner systems would be a porous leachate collection layer (e.g., coarse gravel) that
can be monitored (i.e., interstitial monitoring) for leak detection from the upper liner.
Installation of a dual liner system meeting the specifications will contain and confine the TSCA disposal
unit contents from direct contact with groundwater, equivalent to a 50-foot natural buffer. A 200-foot
thick dense clay confining unit (the Peedee formation) lies beneath the planned TSCA disposal unit
location and shallow surficial aquifer and further limits the potential for migration of PCBs.
Implementation of a dual-liner design along with the presence of the natural clay formation would
prevent releases of PCBs and thus the on-site TSCA disposal unit would not present an unreasonable
risk of injury to health and the environment from PCBs under TSCA and also meet the CERCLA
protectiveness requirement.
A conceptual cross-section for the TSCA disposal unit is shown on Figure 40. The primary components
include the following:
TSCA disposal unit subgrade preparation including grading, compaction, and protection against
desiccation and cracking
A clay or equivalent underlayer to serve as a base for the sealing layer
A geosynthetic, clay, or equivalent sealing liner at the base of the TSCA disposal unit to provide
additional containment of the material inside the unit
A base geomembrane on top of the sealing liner to contain and prevent exfiltration of leachate
from the TSCA disposal unit
A second gravel drainage layer to collect leachate and to divert it to drains at the edge of the
TSCA disposal unit for discharge to the surface
An underdrain system between the bottom of the TSCA disposal unit liner system and
groundwater
Disposed waste surrounded by fill material (daily soil cover)
A clay cap or equivalent layer to contain the disposed material
A geomembrane sealing layer covering the TSCA disposal unit to stop infiltration of
precipitation into the disposed material
A permeable geocomposite drainage layer on top of the geomembrane to divert infiltration to
drains at the sides of the TSCA disposal unit
A drainage system at the edge of the cover to move stormwater runoff away from the TSCA
disposal unit
A layer of topsoil, seeded with vegetation for cover stabilization and to encourage
evapotranspiration of moisture that infiltrates the topsoil cover
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Figure 40: On-site Conceptual TSCA Disposal Unit Cross-Section
Summary of Remedial Alternative Selection
September 2017
amec foster wheeie-
ON-SITE. CONCEPTUAL
TSCAEQUIVALENT
LANDFILL CROSS-SECTION
FOR ILLUSTRATION PURPOSES ONLY
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September 2017
Location
The TSCA disposal unit must meet buffer requirements identified in 15A NCAC 13B.0503(2)(f),
identified as ARARs. Because of the size of the property and a portion being within a 100-year flood
zone there are limited locations on the property where the TSCA disposal unit can be constructed. An
example conceptual TSCA disposal unit layout that would meet disposal volume requirements with a
footprint allowing for up to a 200-foot setback is shown in Figure 41. The selection of the TSCA
disposal unit location on the property will be based on the results of pre-design studies including but not
limited to geotechnical testing and evaluation, structural evaluation, hydrogeological evaluations,
surface hydraulics evaluation, material handling planning, and sequencing of remedial actions. The
potential to place the cell on top of the closed RCRA units or to avoid them will be carefully considered
in the remedial design, based upon the conclusions of the above evaluations. Should the TSCA disposal
unit be placed over these closed RCRA units, its design, construction, monitoring, and maintenance
must be compatible with the intended purpose of these RCRA units, their structural capacity/stability,
and their associated monitoring/maintenance requirements. The evaluation could result in a
determination that the on-site TSCA disposal unit cannot be located at the site due to concerns with
structural integrity and prevention of releases, such that another remedial alternative would have to
selected through a modification of the remedy.
Figure 41: On-site TSCA Disposal Unit Conceptual Layout
CSAPHIC SCALE - IN FEET
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September 2017
Monitoring and Maintenance
It is also possible that a TSCA disposal unit may extend over the retort and cell building pads where
remedial technologies such as ISS or a vertical barrier followed by placement of a soil cap may be
implemented. Should the TSCA disposal unit be placed over the retort and cell building pad areas, its
design, construction, monitoring, and maintenance must be conducted in a manner that will preserve the
protectiveness and effectiveness of selected alternative for the retort and cell building pads.
Long-term monitoring and maintenance for both the on-site TSCA disposal unit and closed-in-place
RCRA units would be conducted in accordance with TSCA and RCRA ARARs.
Ancillary Activities
Site preparation activities would include the construction of access roads, support zones, and staging
areas for personnel, equipment, and material. Clearing and installation of erosion controls would be
required for support and staging areas.
Ancillary activities required to support construction activities include:
cap/excavation area access and preparation,
erosion control,
backfill material delivery and staging,
excavated material staging and handling,
cover soil delivery and staging,
construction waste disposal,
cap placement verification,
waste soil transport and disposal,
stormwater management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
Ambient air would be monitored for dust during construction. Dust control measures would be
implemented, and would include wetting roads, stockpiles, and staging areas. Real-time air monitoring
would be performed during construction to verify compliance with ARARs.
Site-wide long-term maintenance and inspection would be required to evaluate backfill erosion and to
verify cap, TSCA disposal unit, and previously closed RCRA unit performance over time. Long-term
monitoring of groundwater would also be required to confirm TSCA disposal unit and closed RCRA
unit integrity and compliance with ARARs. Periodic maintenance would be carried out as needed to
preserve or restore the integrity of these systems. ICs and ECs would be employed to limit risks to
human and ecological receptors. ICs would consist of deed and land use restrictions in a recorded a
Notice and/or restrictive covenant. ECs would consist of warning signs and fencing. The site is currently
fenced along the west, south, and east property boundaries.
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9.1.4 Alternative A-4: Combination of Capping and Excavation, Off-site Disposal, and ICs/ECs
Estimated Costs:
Capital Cost
$20,453,700
Annual O&M Cost
$31,500
Total Cost
$21,600,000
Total Present Worth Cost
$20,900,000
Estimated Timeframes:
Construction Timeframe
12 months
Time to Achieve RAOs
12 months
This alternative is the same as Alternative A-3, but with off-site disposal of excavated material in an
EPA-approved TSCA chemical waste landfill.
9.1.5 Alternative A-5: Excavation, On-site Disposal, and ICs/ECs
Estimated Costs:
Capital Cost
$12,851,800
Annual O&M Cost
$31,500
Total Cost
$14,000,000
Total Present Worth Cost
$13,300,000
Estimated Timeframes:
Construction Timeframe
18-24 months
Time to Achieve RAOs
18-24 months
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Summary of Remedial Alternative Selection
September 2017
Figure 42: Alternatives A-5 and A-6
RCMEOIA- ALTTRMATIVFa AND *4 - B0EC* EXCAVATION- AND OMITE 0«
DISPOSAL
I CP-MOl TOACMFM SIT - FFASIWLITY STUDY
RIFOF. WOOD, MQETH CAROUNA
mm
DATE: APRIL 21. 201 s
AS SHOWN
This alternative includes:
Excavation of contaminated soil in the Upland Process and Wooded Bottomland Areas
Disposal of excavated material and WWTS in an on-site TSCA disposal unit
Closure of the stormwater conveyance system
Decommissioning of the stormwater treatment system and restoration of the site to natural
drainage following completion of remedial action
Implementation of ICs/ECs
This alternative, although titled as excavation, also includes a limited amount of capping in Area L.
Capping/erosion control would be implemented in the L areas along the berm of the Upland Non-
Process Area. The conceptual remedial plan shown on Figure 42 identifies remedial areas A through M
(minus F and G). Table 88 on page 161 describes each remedial area. The rationale for selecting areas to
be capped or excavated is based on the size/local extent of detected contamination, the magnitude of
PCB and mercury concentrations, and the location/exposure risk.
Remedial activities in the Upland Process Area include excavation of soil areas with mercury or PCB
concentrations that exceed cleanup levels protective of the industrial or construction worker in
accordance with the RAOs. Excavation in the Upland Process Area would also serve to protect the
Wooded Bottomland area by preventing contact of Upland Process Area soil with surface runoff and the
potential migration of soil into the Wooded Bottomland Area. Areas to be excavated include Areas A, B,
C, D, E, J, K, and M. Backfilling of excavated areas to approximately original grade and revegetation
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would also be included in this overall site remedial alternative. Capping and erosion control would occur
in the L Areas, which is located along the steep portion of the Upland Non-Process Area berm. Removal
of L Areas is not recommended due to potential instability of the slope during remedial action.
Capping
In Alternative A-5, a cap would be applied over the L Areas along the berm of the Upland Non-Process
Area impoundments. The anticipated extent of capping for this scenario is shown on Figure 42. The final
cap area footprint in some areas would be confirmed during remedial design sampling. The cap
composition assumed for costing is a protective underlayment of fill soil (compacted in place), a
geosynthetic liner, a protective layer of fill soil on top of the liner soil, plus up to six inches of topsoil to
support revegetation. The actual cap composition and soil layer thicknesses would be evaluated during
the remedial design to meet site-related ARARs.
Excavation
Alternative A-5 consists of excavating Upland Process Areas A, B, C, D, and E and Wooded
Bottomland Areas J, K, and M. Areas A, B, C, D, and E exceed the Upland Process Area Aroclor
1254+Aroclor 1268 surface and subsurface soil cleanup level (11 mg/kg). Areas J exceed the Wooded
Bottomland Area Aroclor 1268 sediment cleanup level (47 mg/kg) and the mercury sediment cleanup
level (0.75 mg/kg). Areas K and M exceed the Wooded Bottomland Area Aroclor 1254+Aroclor 1268
surface soil cleanup level (21 mg/kg). The anticipated extent of excavation for this scenario is shown on
Figure 42. The total in-place excavation volume is estimated to be 26,400 yd3. The actual excavation
footprints of the isolated areas would be confirmed during remedial design sampling. Following
excavation, clean backfill/topsoil would be placed in the areas to restore the ground surface to
approximately pre-excavation grades and the areas would be seeded/revegetated to control erosion.
Removal activities would be conducted as described under Alternative A-2. Excavated and dewatered
materials would be disposed in an on-site TSCA disposal unit designed and constructed as described in
Alternative A-3.
Stormwater Conveyance System
The stormwater conveyance system (I Areas) would be closed by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout. Solids, if removed during closure of the
system, would be dewatered and disposed in an on-site TSCA disposal unit.
Following completion of site-wide remedial activities active stormwater collection and management
would no longer be necessary. Therefore, the existing stormwater treatment system would be
decommissioned and the site returned to natural drainage. Long-term maintenance would include
inspection and repair of erosion controls.
WWTS
WWTS (Areas H) containing PCB concentrations greater than 50 mg/kg are temporarily stockpiled at
the Mercury Cell Building pad and the SWDS. Alternative A-5 includes disposal of the WWTS in an
on-site TSCA disposal unit. The total volume of the stockpiled soil on both the Mercury Cell Building
pad and the SWDS is approximately 23,700 yd3.
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Summaiy of Remedial Alternative Selection
September 2017
On-site TSCA Disposal Unit and Ancillary Activities
Construction of the on-site TSCA disposal unit and ancillary activities would be performed as described
in Alternative A-3.
9.1.6 Alternative A-6: Excavation, Off-site Disposal, and ICs/ECs
Estimated Costs:
Capital Cost
$25,000,000
Annual O&M Cost
$29,000
Total Cost
$25,900,000
Total Present Worth Cost
$25,400,000
Estimated Timeframes:
Construction Timeframe
12 months
Time to Achieve RAOs
12 months
This alternative is the same as that for Alternative A-5, but with off-site disposal of excavated material
in a EPA-approved TSCA chemical waste landfill. The methods used for capping, excavation, closure of
stormwater conveyance system, and ancillary activities are the same as those for Alternative A-5.
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Summary of Remedial Alternative Selection
September 2017
Alternatives for soil in Retort Area and Cell Building Pad Area
The following remedial alternatives were developed for soil associated with the Upland Process Area
Retort Area and Cell Building pads.
9.1.7 Alternative S-l: No Action
Estimated Costs:
Capital Cost
$0
Annual O&M Cost
$0
Total Cost
$0
Total Present Worth Cost
$0
Estimated Timeframes:
Construction Timeframe
0 months
Time to Achieve RAOs
beyond our lifetime
No Action includes no remedial measures or ICs. According to NCP 40 CFR §300.430(e)(6), No Action
is retained for detailed analysis and used as a baseline in comparing alternatives.
9.1.8 Alternative S-2: Capping with Vertical Impermeable Barrier Installation and ICs
Estimated Costs:
Capital Cost
$1,300,000
Annual O&M Cost
see A alternatives
Total Cost
$1,300,000
Total Present Worth Cost
n/a
Estimated Timeframes:
Construction Timeframe
6-12 months
Time to Achieve RAOs
6-12 months
This alternative consists of construction of a vertical barrier, capping of mercury waste and
contaminated soils associated with the Retort and Cell Building pads in Areas F and G, and ICs. Table
88 on page 161 describes these remedial areas. The remedial footprint for these areas is shown on
Figure 43. The remedial footprint shown in this figure may be expanded during remedial design to
include adjacent areas, such as the MESS.
This alternative provides containment of soils with mercury or PCB concentrations that exceed cleanup
levels protective of the industrial or construction worker in accordance with the RAOs in these areas. It
also protects the Wooded Bottomland Area by preventing contact of Upland Process Area soil with
surface runoff and the potential migration of soil into the Wooded Bottomland Area. The purpose of the
cap and vertical barrier is to isolate the soils associated with the Retort and Cell Building pads both
horizontally and vertically. Historically, these soils have not served as a source of mercury or PCBs to
groundwater. This alternative serves as an added measure so that they do not become a source in the
future.
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Vertical Impermeable Barrier Installation
Alternative S-2 consists of the installation of a vertical impermeable barrier around the outside of the
pads. A vertical barrier would span a combined linear distance of approximately 1,100 feet around the
areas of the pads. The barriers would be constructed using augers or other soil mixing equipment to
inject and mix low permeability slurry (e.g., bentonite-cement) into the soil in sequential, overlapping
vertical sections. The barriers would be keyed into the underlying Peedee Formation. Depths to the
Peedee Formation are approximately 15 and 10 feet in Areas F and G, respectively.
Figure 43: Alternative S-2
«EMECHA>_ AL f CfWATfVE W-|C» AND CAPPING VflTW VERTICAL |MPCS*UCAai-:
8ARRJFRIMSTAUA7JQM
LCfMOLTHACHCM 8PTF - FEASIBILITY STUDY
BIEGe.WOOO VQW'H SAROUNA
APPROVAL:
AS SHOWN
Capping
In Alternative S-2, a cap would be installed following vertical perimeter barrier installation. The total
cap area for this alternative is estimated to be about 1.3 acres. The final cap area footprint would be
confirmed during remedial design sampling and may be expanded from that shown in Figure 43.
Capping would be achieved by placing a clay/geomembrane or equivalent RCRA cap system with a
vegetated cover over Areas F and G. Before cap placement, the area would be prepared by leveling in-
ground structures. The cap composition assumed for costing is a protective underlayment of fill soil
(compacted in place), a geosynthetic liner, a protective layer of fill soil on top of the liner soil, plus up to
six inches of topsoil to support revegetation. The actual cap composition and soil layer thicknesses
would be evaluated during the remedial design and will comply with RCRA ARARs for a hazardous
waste landfill final cover as well post-closure care requirements.
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The cell pit area is east of the Cell Building pad as shown on Figure 43. It could potentially contain
mercury residuals; however, no specific data are available to confirm the presence of mercury above
cleanup levels. The cell pit would be drained, the stormwater would be managed through the existing
stormwater collection and treatment system, the pit concrete surfaces would be sealed, and the pit would
be backfilled with structural fill to prevent water accumulation following completion of remedial
activities. A clay/geomembrane or equivalent cap would be placed over the area to isolate the
contaminated soil and will comply with RCRA ARARs for a hazardous waste landfill final cover as well
post-closure care requirements. The actual cap composition and soil layer thicknesses would be
evaluated during the remedial design.
Cap placement activities would be conducted using standard construction equipment (e.g., backhoes,
bulldozers, graders, drill augers, etc.). Topographic survey and GPS instrumentation would be used to
confirm extents and final grades of cap emplacement.
Ancillary Activities
Site preparation activities would include the construction of access roads, support zones, and staging
areas for personnel, equipment, and material. Clearing and installation of erosion controls would be
required for support and staging areas. Ancillary activities required to support construction activities
would include:
remediation area access and preparation,
erosion control,
cap material delivery and staging,
construction waste disposal,
cap placement verification,
storm water management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
Ambient air would be monitored for dust during construction. Dust control measures would be
implemented, and would include wetting roads, stockpiles, and staging areas. Real-time air monitoring
would be performed during construction activities to verify compliance with ARARs.
Long-term inspections would be required to verify cap and barrier performance over time. Periodic
maintenance would be carried out as necessary to preserve or restore the integrity of these systems. ICs
would be employed to limit risks to human and ecological receptors. ICs would consist of deed and land
use restrictions in a recorded a Notice and/or restrictive covenant. Monitoring wells/piezometers within
and outside the vertical barrier would be monitored for hydraulic pressure differences.
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9.1.9 Alternative S-3: In-Situ Stabilization, Capping and ICs
Estimated Costs:
Capital Cost
$2,900,000
Annual O&M Cost
see A alternatives
Total Cost
$2,900,000
Total Present Worth Cost
n/a
Estimated Timeframes:
Construction Timeframe
6-12 months
Time to Achieve RAOs
6-12 months
This alternative consists
Treatment of mercury waste and contaminated soil, considered to be principal threat waste
(PTW), located beneath the former mercury cell building and former retort pad via In-Situ
Stabilization (ISS)
Capping of the areas treated by ISS that meets RCRA Subtitle C landfill final cover ARARs
Table 88 on page 161 describes these remedial areas. The remedial footprint of these areas is shown on
Figure 44. The remedial footprint shown in this figure may be expanded during remedial design to
include adjacent areas, such as the MESS.
This alternative treats soils under and around the pads (10-foot buffer beyond the pad edge). Soil outside
this buffer zone in Area F would be capped. Together, ISS and capping protects industrial/construction
workers through solidification/stabilization of soil with mercury or PCB concentrations that exceed
cleanup levels protective of the industrial or construction worker in accordance with the RAOs in these
areas. It also protects the Wooded Bottomland Area by preventing contact of Upland Process Area soil
with surface runoff and the potential migration of soil into the Wooded Bottomland Area. The purpose
of the ISS is to treat and isolate the mercury waste and contaminated soils through encapsulation.
Historically, these soils have not served as a source of mercury or PCBs to groundwater. This alternative
would serve as an added measure so that they do not become a source in the future.
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Figure 44: Alternative S-3
GRAPHIC SCALE - IN FEET
ISS
Alternative S-3 consists of ISS of the mercury waste and contaminated soil under and around the Retort
Area and Cell Building pads in Areas F and G. The footprint of the both ISS areas would be capped to
minimize infiltration and potential for leaching of contaminants. ISS reagents such as portland cement or
lime/pozzolans (e.g., fly ash and cement kiln dust) or other agents would be selected to reduce the
leachability of COCs through encapsulation, binding, and/or limiting the hydraulic conductivity of the
final solidified matrix. A treatability study would be performed during remedial design to develop a
suitable mix design to achieve post-solidification leachability goals and establish parameters for field
performance testing (e.g., compressive strength, hydraulic conductivity, and /or wet/dry cycle
durability). Various mix agents, such as sulfides and activated carbon, will be evaluated during the
treatability study to select the optimum mixing agent.
During field implementation, the ISS agents are injected into the subsurface environment and mixed
with the soil using augers or other soil mixing equipment. The outside clean perimeter of the ISS area
may be augured first to act as a vertical barrier and avoid migration of COCs during implementation.
Performance sampling is conducted at a pre-specified frequency, with samples collected from various
depth intervals during mixing. The individual samples are visually examined to confirm mix
homogeneity and then composited into cylinders representing the depth range of the aliquots. The
cylinders are cured and analyzed per the performance testing plan.
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The cell pit in Area G would be drained and the collected stormwater would be managed through the
existing stormwater collection and treatment system. The pit concrete would be pulverized and solidified
as part of the ISS area. The addition of solidification agents and physical mixing may increase the
volume of the treated soils, and this volume would be solidified and remain within the treated area
footprint. The potential increase in volume will be considered during the design phase. The total treated
in-situ volume is estimated to be 15,500 yd3.
Capping
In Alternative S-3, a cap would be installed over Areas F and G following ISS implementation. The total
cap area for this alternative is estimated to be about 1.3 acres. The final cap area footprint would be
confirmed during remedial design sampling and may be expanded from that shown in Figure 44, as
appropriate.
Capping would be achieved by placing a clay/geomembrane or equivalent cap system with a vegetated
cover over Areas F and G. Before cap placement, the area would be prepared by leveling in-ground
structures. A composite clay/geomembrane/cover soil or equivalent cap would be placed over the area to
isolate the waste and contaminated soil and will comply with RCRA ARARs for a hazardous waste
landfill final cover as well post-closure care requirements. The cap composition assumed for costing is a
protective underlayment of fill soil (compacted in place), a geosynthetic liner, a protective layer of fill
soil on top of the liner soil, plus up to six inches of topsoil to support revegetation. The actual cap
composition and soil layer thicknesses would be evaluated during the remedial design.
Cap placement activities would be conducted using standard construction equipment (e.g., backhoes,
bulldozers, graders, drill augers, etc.). Topographic survey and GPS instrumentation would be used to
confirm extents and final grades of cap emplacement.
Ancillary Activities
Site preparation activities would include the construction of:
access roads,
support zones, and
staging areas for personnel, equipment, and material.
Clearing and installation of erosion controls would be required for support and staging areas.
Ancillary activities required to support construction activities include:
area access and preparation,
erosion control,
reagent material delivery and staging,
construction waste disposal,
stormwater management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
Ambient air would be monitored for dust during construction. Dust control measures would be
implemented, and would include wetting roads, stockpiles, and staging areas. Real-time air monitoring
would be performed during construction activities to verify compliance with ARARs. Inspections would
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be required to verify system performance over time. ICs would be employed to limit risks to human and
ecological receptors. ICs would consist of deed and land use restrictions.
9.1.10 Alternative S-4: Excavation and Off-site Treatment and Disposal
Estimated Costs:
Capital Cost
$56,000,000
Annual O&M Cost
see A alternatives
Total Cost
$56,000,000
Total Present Worth Cost
n/a
Estimated Timeframes:
Construction Timeframe
7-8 years
Time to Achieve RAOs
7-8 years
This alternative includes ICs, excavation of the soils associated with the Retort Area and Cell Building
pads in Areas F and G, and off-site treatment and disposal of excavated material. Table 88 on page 161
describes these remedial areas. The remedial footprint of these areas is shown on Figure 45. This
alternative involves removal, treatment, and disposal of soils with mercury or PCB concentrations that
exceed cleanup levels protective of the industrial or construction worker in accordance with the RAOs in
these areas. It also protects the Wooded Bottomland Area by preventing contact of Upland Process Area
soil with surface runoff and the potential migration of soil into the Wooded Bottomland Area.
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September 2017
Figure 45: Alternative S-4
Excavation
Alternative S-4 consists of excavating the soils that exceed the cleanup levels for the UPA. Excavation
depths are 15 and 10 feet near the Retort and Cell Building pads, respectively. The total in-place
excavation volume is estimated to be 25,000 yd3. Approximately 15,500 yd3 of the mercury wastes and
contaminated soil beneath the Retort Area and Cell Building pads would go to an off-site approved
RCRA treatment and disposal facility; 9,500 yd3 of the excavated volume from around the Area F Retort
pad would go to an off-site, EPA-approved landfill for TSCA and/or RCRA waste. As part of
remediation in the former Cell Building area, the cell pit would be drained and the collected stormwater
would be managed through the existing stormwater collection and treatment system. The pit concrete
would be demolished and managed as part of the excavated waste material. Following excavation, clean
backfill/topsoil would be placed in the areas to restore the ground surface to approximately pre-
excavation grades, and the areas would be seeded/revegetated.
Removal activities would be conducted using standard construction equipment (e.g., backhoes,
bulldozers) equipped with GPS instrumentation to monitor the removal progress and confirm that
excavations meet the established horizontal and vertical goals. Shoring of the excavated area would be
required until the area is backfilled. Backfill would be placed to predetermined elevations using
conventional earthmoving equipment. Seeding and erosion controls would be implemented upon
verification that backfill design elevations have been met.
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Where required, excavated soil would be stockpiled within a materials staging area prior to
transportation. Potentially impacted stormwater would be managed through the existing stormwater
conveyance and treatment system.
Off-site Treatment and Disposal
If excavated waste and soils are hazardous due to characteristic toxicity and mercury is present at
concentrations greater than or equal to 260 mg/kg, EPA requires treatment by retorting/incineration
before disposal in accordance with land ban restrictions for mercury characteristic hazardous waste as
defined in 40 CFR §268.40 and §268.48. Therefore, excavated material would be transported to an off-
site retort/incineration and disposal facility approved by EPA to accept both mercury- and PCB-
containing wastes. The number of such facilities in the U.S. is very limited. One retort facility operated
by Waste Management Mercury Waste, Inc. in Union Grove, Wisconsin, has been identified as willing
to accept mixed waste containing both mercury and PCBs if the PCB concentrations are less than 50
mg/kg. This facility is approximately 985 miles from the site and has a maximum capacity of 40 yd3 of
material per week. Disposal facilities may reject the excavated material upon profiling if PCB
concentrations are greater than 50 mg/kg so that off-site treatment and/or disposal options are not
available.
Soil associated with the Retort Area and Cell Building pads may differ in quality in that they potentially
contain higher mercury concentrations that may be hazardous by toxicity characteristic. Therefore, this
soil would be handled differently than the soil outside the Area F Retort pad. The soil beneath the Retort
Area and Cell Building pads would go to an off-site treatment and disposal facility; and the soil outside
of the Area F Retort pad would go to an off-site EPA-approved TSCA and/or RCRA landfill.
Ancillary Activities
Site preparation activities would include construction of
access roads,
support zones, and
staging areas for personnel, equipment, and material.
Clearing and installation of erosion controls would be required for support and staging areas.
Ancillary activities required to support construction activities include:
excavation area access and preparation,
erosion control,
backfill material delivery and staging,
long-term excavated material staging and handling while awaiting transport (see
Implementability discussion below),
construction waste disposal,
waste soil transport and disposal,
stormwater management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
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Ambient air would be monitored for dust during construction. Dust control measures would be
implemented, and would include wetting roads, stockpiles, and staging areas. Real-time air monitoring
would be performed during construction activities to verify compliance with ARARs.
9.2 Applicable or Relevant and Appropriate Requirements (ARARs)
NCP §300.430(e)(9)(iii)(B) states: "Compliance with ARARs. The alternatives shall be assessed to
determine whether they attain applicable or relevant and appropriate requirements under federal
environmental laws and state environmental or facility siting laws or provide grounds for invoking one
of the waivers under paragraph (f)(l)(ii)(C) of this section."
There are three broad categories of ARARs: chemical-specific, location-specific, and action-specific.
Lead and support regulatory agencies may, as appropriate, identify additional advisories, criteria, or To-
Be-Considered (TBC) guidance for a particular site. TBCs are not legally binding and lack the status of
ARARs. The remedial alternatives are screened against their ability to meet ARARs and TBCs.
Under CERCLA Section 121(e)(1), federal, state, or local permits are not required for the portion of any
removal or remedial action conducted entirely on-site as defined in 40 CFR § 300.5. See also 40 CFR §§
300.400(e)(1) & (2). In addition, CERCLA actions must only comply with the "substantive
requirements," not the administrative requirements of regulations. Administrative requirements include
permit applications, reporting, record keeping, and consultation with administrative bodies. Although
consultation with state and federal agencies responsible for issuing permits is not required, it is
recommended to consult with the agencies for determining compliance with certain requirements, such
as those typically identified as Location-Specific ARARs.
Applicable requirements, as defined in 40 CFR § 300.5, means those cleanup standards, standards of
control, and other substantive requirements, criteria, or limitations promulgated under federal
environmental, state environmental, or state facility siting laws that specifically address a hazardous
substance, pollutant, or contaminant, remedial action, location, or other circumstance at a CERCLA site.
Only those state standards that are identified by the state in a timely manner and that are more stringent
than federal requirements may be applicable. Relevant and appropriate requirements, as defined in 40
CFR § 300.5, means those cleanup standards, standards of control, and other substantive requirements,
criteria, or limitations promulgated under federal environmental, state environmental, or state
facility siting laws that, while not "applicable" to a hazardous substance, pollutant, or contaminant,
remedial action, location, or other circumstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at a CERCLA site that their use is well-suited to the particular
site. Only those state standards that are identified by the state in a timely manner and that are more
stringent than federal requirements may be relevant and appropriate.
Per 40 CFR § 300.400(g)(5), only those state standards which are promulgated, are identified in a timely
manner, and are more stringent than federal requirements may be applicable or relevant and appropriate.
For the purposes of identification and notification of promulgated state standards, the term
"promulgated" means that the standards are of general applicability and are legally enforceable. State
ARARs are considered more stringent where there is no corresponding federal ARAR, where the state
ARAR provides a more stringent concentration of a contaminant, or the where a state ARAR is broader
in scope than a federal requirement.
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In addition to ARARs, the lead and support agencies may, as appropriate, identify other advisories,
criteria, or guidance to be considered for a particular release. The To-Be-Considered (TBC) category
consists of advisories, criteria, or guidance that were developed by EPA, other federal agencies, or states
that may be useful in developing CERCLA remedies. See 40 CFR. § 300.400(g)(3). TBCs can be used in
the absence of ARARs, when ARARs are insufficient to develop cleanup goals, or when multiple
contaminants may be posing a cumulative risk.
In accordance with 40 CFR § 300.400(g), EPA and NCDEQ have identified the potential ARARs and
TBCs for the evaluated alternatives. The majority were included in the FS. The final ARARs for the
selected remedy are included in Appendix A - ARARs.
9.3 Common Elements and Distinguishing Features of Each Alternative
9.3.1 Components
Components common to all active remedial alternatives include ICs such as deed restrictions and ECs
such as erosion control and fencing. Each remedial alternative also includes long-term monitoring for
site media including groundwater and surface water. In addition, the former RCRA units that were
closed will be monitored and maintained in accordance with RCRA ARARs for post-closure care of a
hazardous waste surface impoundment. The components and distinguishing features for the A-
alternatives and S- alternatives are summarized in Table 89 and Table 90 respectively.
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Table 89: Alternatives A1-A6 Common Elements and Distinguishing Features
Remedial
Area
A-l
A-2a
A-2b
A-3
A-4
A-5
A-6
Area Description
NO
ACTION
CAPPING
WITH LIMITED
EXCAVATION,
OFF-SITE
DISPOSAL,
AND ICs/ECs
same as 2a
except forH
area
COMBINATION OF
CAPPING AND
EXCAVATION, ON-
SITI DISPOSAL, AND
ICs/ECs
COMBINATION
OF CAPPI NG
AND
EXCAVATION,
ON-SITE
DISPOSAL, AND
ICs/ECs
EXCAVATION,
ON-SITE
DISPOSAL,
AND ICs/ECs
EXCAVATION,
OFF-SITE
DISPOSAL,
AND ICs/ECs
A
Area west of CBP (PCB 25-
49 mg/kg)
nothing
cap
excavate, on-
site landfill
excavate, off-
site disposal
B
Southwest corner of WWTP
nothing
excavate, off-site disposal
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
C
Membrane Plant Ancilliary
Areas (PCB 25-49 mg/kg)
nothing
cap
excavate, on-
site landfill
excavate, off-
site disposal
D
Fill Area (PCB >50 mg/kg)
nothing
cap
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
E
Areas Northeast of Cell
Building Pad
nothing
excavate, off-site disposal
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
H
Waste Water Treatment
Solids
nothing
off-site
disposal
LTTD
treatment
on-site landfill
off-site disposal
on-site Landfill
off-site
disposal
1
Stormwater Conveyance
System
nothing
cleaned and sealed
J
Wooded Bottomland Areas
(Including Drainage
Pathways)
nothing
excavate, off-site disposal
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
K
Wooded Bottomland Area
(North of Fill Area)
nothing
excavate, off-site disposal
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
L
Areas Northeast Corner of
ON P and Southeast Corner
of NRB
nothing
cap/erosion control
M
Wooded Bottomland Area
(North of Fill Area)
nothing
excavate, off-site disposal
excavate, on-site
landfill
excavate, off-
site disposal
excavate, on-
site landfill
excavate, off-
site disposal
Threshold
criteria
1. Protectiveness
No
Yes
Yes
Yes
Yes
Yes
Yes
2. ARAR compliance
No
Yes
Yes
Yes
Yes
Yes
Yes
Balancing
criteria
3. Long-term
No
Yes
Yes
Yes
Yes
Yes
Yes
4. TMV
No
TMV
TMV
TM
TMV
TM
TMV
5. Short-term
No
Yes
Yes
Yes
Yes
Yes
Yes
6. Implementability
0 months
12 months
12 months
18-24 months
12 months
18-24 months
12 months
7. Cost
$ -
$ 19,700,000
$ 21,300,000
$ 13,300,000
S 21,600,000
$ 14,000,000
$ 25,900,000
Modifying
Criteria
8. State Acceptance
No
Yes
Yes
Yes
Yes
Yes
Yes
9. Community Acceptance
No Comments received from community members.
Notes:
ECs = Engineering Controls
ICs = Institutional Controls
LTTD = low temperature thermal desporption
mg/kg = milligrams per kilogram
TMV = toxicity, mobility, volume
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September 2017
Table 90: Alternatives S1-S4 Common Elements and Distinguishing Features
Remedial
Area
Area Description
S-l
S-2
S-3
S-4
NO ACTION
CAPPING WITH
VERTICAL
IMPERMEABLE
BARRIER
INSTALLATION
AND ICS
ISS, CAPPING,
AND ICS
EXCAVATION
AND OFF-SITE
TREATMENT
AND DISPOSAL
F
Retort Area
capping, vertical
barrier
capping, ISS
excavate, off-
site Treatment
and disposal
G
Cell Building Pad
nothing
Threshold
criteria
1. Protectiveness
No
Yes
Yes
Yes
2. ARAR compliance
No
Yes
Yes
Uncertain
Balancing
criteria
3. Long-term
No
Yes
Yes
Yes
4. TMV
No
TM
TM
TMV
5. Short-term
No
Yes
Yes
Yes
6. Implementability
0 months
6-12 months
6-12 months
7-8 years
7. Cost
$
$ 1,300,000
$ 2,900,000
$ 56,000,000
Modifying
Criteria
8. State Acceptance
No
Yes
Yes
Yes
9. Community Acceptance
No comments received from community members.
Notes:
ICs = Institutional Controls
ISS = In-Situ Stabilization
TMV = Toxicity, Mobility, Volume
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September 2017
9.3.2 Volumes
Table 91 illustrates the distinguishing differences regarding volumes to be capped, excavated, off-site
treatment or disposal, and on-site TSCA disposal unit.
Table 91: Volume Comparisons by Remedy Mode
Alternative
Acres
Capped
Excavated
Volume
(Yd3)
WWTS
Volume
(yd3)
Off-site
Disposal or
Treatment
(Yd3)
On-site
TSCA
Disposal
Unit (yd3)
A-l
0
0
23,700
0
0
A-2
2.4
10,900
23,700
34,600
0
A-3
1.7
15,400
23,700
0
39,100
A-4
1.7
15,400
23,700
39,100
0
A-5
0.02
26,400
23,700
0
50,100
A-6
0.02
26,400
23,700
50,100
0
S-l
0
0
N/A
0
0
S-2
1.3
0
N/A
0
0
S-3
1.3
0
N/A
0
0
S-4
0
25,000
N/A
25,000
0
Notes:
N/A
not applicable (addressed in A- alternatives)
WWTS
Wastewater Treatment Solids
yd3
cubic yards
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Summary of Remedial Alternative Selection
September 2017
9.33 Costs and Timeframes
Table 92 illustrates the similarities and differences in timeframes and estimated costs.
Table 92: Estimated Cost and Timeframes
Estimated Costs
Timeframes (years)
Total
Annual
Present
Capital
O&M
Total
Worth
Construction
To Achieve RAOs
A-l
$0
$0
$0
$0
0
beyond our lifetime
A-2a
$18,647,700
$31,500
$19,700,000
$19,000)000
1
1
A-2b
$20,180,300
$31,500
$21,300,000
$20,600,000
1
1
A-3
$12,122,700
$36,500
$13,300,000
$12,600,000
1.5-2
1.5-2
A-4
$20,453,700
$31,500
$21,600,000
$20,900,000
1
1
A-5
$12,851,800
$31,500
$14,000,000
$13,300,000
1.5-2
1.5-2
A-6
$25,000,000
$29,000
$25,900,000
$25,400,000
1
1
S-l
$0
*
$0
$0
0
beyond our lifetime
S-2
$1,300,000
*
$1,300,000
N/A
0.5-1
0.5-1
S-3
$2,900,000
*
$2,900,000
N/A
0.5-1
0.5-1
S-4
$56,000,000
*
$56,000,000
N/A
7-8
7-8
Notes:
*
Annual O&M costs are included in the A- alternatives
N/A
Not Applicable
RAOs
Remedial Action Objectives
9.3.4 NCP Criteria
All of the alternatives except for the No Action alternatives are protective of human health and the
environment.
All alternatives comply with ARARs, with the waiver invoked in this ROD for Alternatives A-3 and A-
5. The waiver used is TSCA regulation 40 CFR §761.75(c)(4) for construction of a chemical waste
landfill. The necessity for this waiver is due to not meeting the 50-foot depth requirement from the
TSCA disposal unit bottom liner to groundwater. Due to the engineered design of the TSCA disposal
unit and natural clay formation present at the site, potential releases of PCBs will be addressed in a
manner that does not present an unreasonable risk of injury to human health and the environment under
TSCA and will be protective of human health and the environment under CERCLA.
All of the alternatives reduce mobility to some extent. S-3 which includes ISS as on-site treatment, will
reduce toxicity and mobility of PTW in areas F and G. In addition, alternatives A-2, A-4, A-6 and S-4
also reduce volume due to off-site transportation, treatment and disposal.
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Summary of Remedial Alternative Selection
September 2017
All of the alternatives include minimal to moderate short-term risks. These risks are primarily to impacts
to ecological receptors, risks to the public during transportation of wastes to disposal facilities.
All of the alternatives are implementable, however implementation of alternative S-4 will be difficult
due to the treatment facility's limitations on how much waste they can accept/treat per day and the large
volume estimated under this alternative.
Alternative costs range from $0 to $25.9 million for the overall site alternatives and $0 to $56 million
for the S- alternatives.
Remedial Action timeframes range from 12 to 24 months of the overall site alternatives and 6 months to
8 years (S-4) for the S- alternatives.
NCDEQ supports EPA's selected remedy. EPA did not receive any comments from community
members regarding the proposed remedy.
9.4 Expected Outcomes of Each Alternative
After completion of the remedial action, the land use will be limited to industrial use or ecological
habitat for each alternative. This is primarily due to being surrounded on three sides by IP and the fourth
side bordering the Cape Fear River. As discussed in Section 6.0, groundwater at the site cannot be used
for potable purposes. This will remain the same after completion of the remedial action, regardless of
which alternative is selected.
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Summary of Remedial Alternative Selection
September 2017
10.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 400.430(f)(5)(i) of the NCP requires that the ROD explain how the nine evaluation criteria in
NCP §300.430(e)(9)(iii) were used to select the remedy. The nine criteria are divided into three
categories: threshold criteria (must be met), balancing criteria (basis for alternative selection), and
modifying criteria (applied after the public comment period ends for the Proposed Plan). The specific
evaluation criteria that fall under each of these categories are listed below:
Threshold Criteria
Overall protection of human health and the environment
Compliance with ARARs
Balancing Criteria
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Modifying Criteria
State Acceptance
Community Acceptance
The remedial alternatives were evaluated for the criteria and then compared with one another to identify
their respective strengths and weaknesses. Reduction of toxicity, mobility and volume has been
evaluated with and without treatment in the FS, with the understanding that EPA has a preference for
treatment, when applicable. Table 93 and Table 94 summarize the comparative analysis for the A-
alternatives and the S-alternatives, respectively.
Sections 10.1 through 10.9 discuss each criterion in detail. As recommended in Highlight 6-23 in^4
Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection
Decision Documents, the discussion of each criterion presents each alternative in decreasing order from
the most to least advantageous. Where alternatives have equal advantages, they are listed in numerical
name order.
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Summary of Remedial Alternative Selection
September 2017
Table 93: Comparative Analysis Summary for A-l through A-6
Remedial
Area
Area Description
A-l
A-2a
A-2b
A-3
A-4
A-5
A-6
NO
ACTION
CAPPING
WITH LIMITED
EXCAVATION,
OFF-SITE
DISPOSAL,
AND ICs/ECs
same as 2a
except for H
area
COMBINATION OF
CAPPING AND
EXCAVATION, ON-
SITE DISPOSAL, AND
ICs/ECs
COMBINATION
OF CAPPING
AND
EXCAVATION,
ON-SITE
DISPOSAL, AND
ICs/ECs
EXCAVATION,
ON-SITE
DISPOSAL,
AND ICs/ECs
EXCAVATION,
OFF-SITE
DISPOSAL,
AND ICs/ECs
Threshold
criteria
1 Protectiveness
No
Yes
Yes
Yes
Yes
Yes
Yes
2. ARAR compliance
No
Yes
Yes
Yes
Yes
Yes
Yes
Balancing
criteria
3. Long-term
No
Yes
Yes
Yes
Yes
Yes
Yes
4. TMV
No
TMV
TMV
TM
TMV
TM
TMV
5. Short-term
No
Yes
Yes
Yes
Yes
Yes
Yes
16. Implementability
0 months
12 months
12 months
18-24 months
12 months
18-24 months
12 months
7. Cost
S -
S 19,700,000
S 21,300,000
S 13,300,000
$ 21,600,000
$ 14,000,000
S 25,900,000
Modifying
Criteria
8. State Acceptance
No
Yes
Yes
Yes
Yes
Yes
Yes
9. Community Acceptance
No Comments received from community members.
Notes:
ECs = Engineering Controls
ICs = Institutional Controls
LTTD = low temperature thermal desporption
mg/kg = milligrams per kilogram
TMV = toxicity, mobility, volume
Table 94: Comparative Analysis Summary for S-l through S-4
Remedial
Area
Area Description
S-l
S-2
S-3
S-4
NO ACTION
CAPPING WITH
VERTICAL
IMPERMEABLE
BARRIER
INSTALLATION
AND ICs
ISS, CAPPING,
AND ICs
EXCAVATION
AND OFF-SITE
TREATMENT
AND DISPOSAL
Threshold
criteria
1. Protectiveness
No
Yes
Yes
Yes
2. ARAR compliance
No
Yes
Yes
Uncertain
Balancing
criteria
3. Long-term
No
Yes
Yes
Yes
4. TMV
No
TM
TM
TMV
5. Short-term
No
Yes
Yes
Yes
6. Implementability
0 months
6-12 months
5-12 months
7-8 years
7. Cost
$
$ 1,300,000
$ 2,900,000
$ 56,000,000
Modifying
Criteria
8. State Acceptance
No
Yes
Yes
Yes
9. Community Acceptance
No comments received from community members.
Notes:
ICs = Institutional Controls
ISS = 1 n-Situ Stabilization
TMV = Toxicity, Mobility, Volume
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Summary of Remedial Alternative Selection
September 2017
10.1 Overall Protection of Human Health and the Environment
NCP §300.430(e)(9)(iii)(A) states: "Overall protection of human health and the environment.
Alternatives shall be assessed to determine whether they can adequately protect human health and the
environment, in both the short- and long-term, from unacceptable risks posed by hazardous substances,
pollutants, or contaminants present at the site by eliminating, reducing, or controlling exposures to levels
established during development of remediation goals consistent with §300.430(e)(2)(i). Overall
protection of human health and the environment draws on the assessments of other evaluation criteria,
especially long-term effectiveness and permanence, short-term effectiveness, and compliance with
ARARs."'
Table 95 provides a summary comparison of each alternative regarding the criteria of overall protection.
Table 95: Criteria 1 - Overall Protection Summary
Alternative
Overall
Protection?
Overall Site Alternatives
A-l No Action
No
A-2a Capping with Limited Excavation, Off-site Disposal, and ICs/ECs
Yes
A-2b same as A-2a except for WWTS treated with LTTD
Yes
A-3 Combination of Capping and Excavation, On-site Disposal and ICs/ECs
Yes
A-4 Combination of Capping and Excavation, Off-site Disposal, and ICs/ECs
Yes
A-5 Excavation, On-site Disposal, and ICs/ECs
Yes
A-6 Excavation, Off-site Disposal, and ICs/ECs
Yes
Soil Beneath Retort Pad and Mercury Cell Building Pad Alternatives
S-l No Action
feif jtS'3 L
No
S-2 Capping with Vertical Impermeable Barrier Installation and ICs
Yes
S-3 In-Situ Stabilization, Capping and ICs
Yes
S-4 Excavation, Off-site Treatment and Disposal
Yes
Notes:
Green background indicates that the alternative meets the criteria of that column
Red background indicates that the alternative does not meet the criteria.
ECs = Engineering Controls
ICs = Institutional Controls
LTTD = low temperature thermal desorption
WWTS = Waste Water Treatment Solids
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Summary of Remedial Alternative Selection
September 2017
10.1.1 A- Alternatives
All of the A- alternatives, except A-l, provide overall protection. Further discussion on each alternative
follows.
Alternative A-2 provides overall protectiveness. Capping isolates and prevents erosion and direct
exposure of human and ecological receptors to COCs in soil. Excavation and backfilling remove COC-
impacted material and protect human and ecological receptors from potential exposure to residual COCs
in soil and sediment. Alternative-2b includes a smaller volume of contaminated material that would be
transported through communities to an off-site landfill. Therefore, it presents less of a short-term risk to
community members than Alternative-2a. ICs control access and further limit exposure to human
receptors.
Alternative A-3 provides overall protectiveness. Capping isolates and prevents erosion and direct
exposure of human and ecological receptors to COCs in soil. Excavation and backfilling remove COC-
impacted material and protect human and ecological receptors from potential exposure to residual COCs
in soil and sediment. Containment of excavated material in an on-site TSCA disposal unit prevents its
erosion and migration, and precludes further exposure to human and ecological receptors. On-site
disposal limits the short-term impacts to community members. ICs control access and further limit
exposure to human receptors.
Alternative A-4 provides overall protectiveness. Capping isolates and prevents erosion and direct
exposure of human and ecological receptors to COCs in soil. Excavation and backfilling remove COC-
impacted material and protect human and ecological receptors from potential exposure to residual COCs
in soil and sediment. Contaminated material would be transported through communities to an off-site
landfill; therefore, it presents short-term risks to community members. ICs control access and further
limit exposure to human receptors.
Alternative A-5 provides overall protectiveness. It includes the largest volume excavated to remove
COC-impacted material. Excavation and backfill protect on-site human and ecological receptors from
potential exposure to residual COCs in soil and sediment. Containment of excavated material in an on-
site TSCA disposal unit prevents erosion and migration, and precludes further exposure to human and
ecological receptors. On-site disposal limits the short-term impacts to community members. ICs control
access and further limit exposure to human receptors.
Alternative A-6 provides overall protectiveness. Excavation and backfilling remove COC-impacted
material and protect human and ecological receptors from potential exposure to residual COCs in soil
and sediment. This alternative includes the largest volume of contaminated material that would be
transported through communities to an off-site landfill; therefore, it presents short-term risks to
community members. ICs control access and further limit exposure to human receptors.
10.1.2 S- Alternatives
All of the S- alternatives, except S-l, provide overall protectiveness. Further discussion on each
alternative follows.
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Summary of Remedial Alternative Selection
September 2017
Alternative S-2 provides overall protectiveness. Containment by a vertical barrier/cap system isolates
and prevents erosion and direct exposure of human and ecological receptors to mercury and PCBs in
soil. It would also control migration of mercury and PCBs in groundwater. ICs control access and
further limit exposure to human receptors.
Alternative S-3 provides overall protectiveness. ISS treats the soil to eliminate potential future mobility
and prevent erosion and potential exposure to COCs in soil to human receptors. ICs control access and
further limit exposure to human receptors.
Alternative S-4 provides overall protectiveness. Excavation, treatment, disposal, and backfilling remove
COC-impacted material and protect human and ecological receptors from potential exposure to residual
COCs in soil. The long duration to implement the remedy and the volume of contaminated material that
would be transported off-site makes this alternative have the highest level of short-term risk to workers
and community members. ICs control access and further limit exposure to human receptors.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
NCP §300.430(e)(9)(iii)(B) states: "Compliance with ARARs. The alternatives shall be assessed to
determine whether they attain applicable or relevant and appropriate requirements under federal
environmental laws and state environmental or facility siting laws or provide grounds for invoking one
of the waivers under paragraph (f)(l)(ii)(C) of this section."
Section 9.2 explains the different types of ARARs. The majority of ARARs developed for all of the
alternatives evaluated are included in the FS. Those were refined further for the selected remedy and are
included in APPENDIX A - ARARs.
Table 96 summarizes whether or not each alternative complies with ARARs. The evaluation is described
further in Sections 10.2.1 and 10.2.2.
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Summary of Remedial Alternative Selection
September 2017
Table 96: Criteria 2 - Compliance with ARARs Summary
Alternative
Compliance with
ARARs?
Overall Site Alternatives
A-l No Action
No
A-2a Capping with Limited Excavation, Off-site Disposal, and ICs/ECs
Yes
A-2b same as A-2a except for WWTS treated with LTTD
Yes
A-3 Combination of Capping and Excavation, On-site Disposal and ICs/ECs
Yes
A-4 Combination of Capping and Excavation, Off-site Disposal, and ICs/ECs
Yes
A-5 Excavation, On-site Disposal, and ICs/ECs
Yes
A-6 Excavation, Off-site Disposal, and ICs/ECs
Yes
Soil Beneath Retort Pad and Mercury Cell Building Pad Alternatives
S-l No Action
No
S-2 Capping with Vertical Impermeable Barrier Installation and ICs
Yes
S-3 In-Situ Stabilization, Capping and ICs
Yes
S-4 Excavation, Off-site Treatment and Disposal
TBD - dependent on
waste profiling data
Notes:
Green background indicates that the alternative meets the criteria of that column
Yellow background indicates that additional information is needed to ensure the alternative complies with ARARs.
Red background indicates that the alternative does not meet the criteria
ARARs = Applicable or Relevant and Appropriate Requirements
ECs = Engineering Controls
ICs = Institutional Controls
TBD = to be determined
TSCA = Toxic Substances Control Act
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Summary of Remedial Alternative Selection
September 2017
10.2.1 A- alternatives
All alternatives except for A-l comply with ARARs. For alternatives A-3 and A-5, a waiver under
TSCA regulation 40 CFR §761.75(c)(4) is being applied at this site for the TSCA chemical waste
landfill requirement of a depth of 50 feet between the TSCA disposal unit bottom liner and groundwater.
10.2.2 S- alternatives
Alternatives S-2 and S-3 comply with ARARs. Alternative S-4 complies with ARARs with uncertainty.
If PCB concentrations in excavated material exceed 50 mg/kg, compliance by treatment and disposal
facilities may not allow off-site retort/incineration. The concentrations of PCBs in these soils are not
fully known because no samples beneath the pads are available. Therefore, compliance with ARARs is
not certain. Alternative S-l does not comply with ARARs.
10.3 Long-Term Effectiveness and Permanence
NCP §300.430(e)(9)(iii)(C) states: "Long-term effectiveness and permanence. Alternatives shall be
assessed for the long-term effectiveness and permanence they afford, along with the degree of certainty
that the alternative will prove successful. Factors that shall be considered, as appropriate, include the
following:
(7) Magnitude of residual risk remaining from untreated waste or treatment residuals remaining at
the conclusion of the remedial activities. The characteristics of the residuals should be considered to
the degree that they remain hazardous, taking into account their volume, toxicity, mobility, and
propensity to bioaccumulate.
(2) Adequacy and reliability of controls such as containment systems and institutional controls that
are necessary to manage treatment residuals and untreated waste. This factor addresses in particular
the uncertainties associated with land disposal for providing long-term protection from residuals; the
assessment of the potential need to replace technical components of the alternative, such as a cap, a
slurry wall, or a treatment system; and the potential exposure pathways and risks posed should the
remedial action need replacement."
Table 97 summarizes whether or not each alternative provides long-term effectiveness and permanence
and includes the volume of contaminated material that will be treated or disposed. The evaluation is
described further in Sections 10.3.1 and 10.3.2.
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Summary of Remedial Alternative Selection
September 2017
Table 97: Criteria 3 - Long-Term Effectiveness and Permanence Summary
Alternative
Volume
Treated or
Disposed*
Long-Term
Effectiveness
Overall Site Alternatives
A-l No Action
-
No
A-2a Capping with Limited Excavation, Off-site Disposal, and ICs/ECs
34,600
Yes
A-2b same as A-2a except for WWTS treated with LTTD
34,600
Yes
A-3 Combination of Capping and Excavation, On-site Disposal and ICs/ECs
39,100
Yes
Combination of Capping and Excavation, Off-site Disposal, and
ICs/ECs
39,100
Yes
A-5 Excavation, On-site Disposal, and ICs/ECs
50,100
Yes
A-6 Excavation, Off-site Disposal, and ICs/ECs
50,100
Yes
Soil Beneath Retort Pad and Mercury Cell Building Pad Alternatives
S-l No Action
-
No
S-2 Capping with Vertical Impermeable Barrier Installation and ICs
-
Yes
S-3 In-Situ Stabilization, Capping and ICs
25,000
Yes
S-4 Excavation, Off-site Treatment and Disposal
25,000
Yes
Notes:
* volume units are cubic yards
Green background indicates that the alternative meets the criteria of that column
Red background indicates that the alternative does not meet the criteria.
ECs = Engineering Controls
ICs = Institutional Controls
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Summary of Remedial Alternative Selection
September 2017
10.3.1 A- alternatives
Alternatives A-2 through A-6 are effective and permanent long-term remedial solutions. They all reduce
risks at the site to varying degrees. The controls needed are adequate and reliable.
Alternative A-2 will treat or dispose of approximately 34,600 yd3 of waste and will cap 2.4 acres. It will
require the following controls:
ICs to limit disturbance of the backfill/cover soil in excavated areas;
ICs to limit disturbance of the caps
inspections/maintenance of erosion controls and revegetated areas; and
groundwater monitoring to confirm remedy protectiveness.
Alternative A-3 will treat or dispose of approximately 39,100 yd3 of waste and will cap 1.7 acres. It will
require the following controls:
ICs to limit disturbance of the backfill/cover soil in excavated areas;
ICs to limit disturbance of the caps
ICs to limit disturbance of the TSCA disposal unit cap and cover soil
inspections/maintenance of erosion controls and revegetated areas; and
groundwater monitoring to confirm remedy protectiveness.
Alternative A-4 will treat or dispose of approximately 39,100 yd3 of waste and will cap 1.7 acres. This
alternative will require the same controls as Alternative A-2.
Alternative A-5 will excavate and place into an on-site TSCA disposal unit approximately 50,100 yd3 of
waste. This alternative will require the same controls as Alternative A-3.
Alternative A-6 will treat or dispose of the highest volume of waste (approximately 50,100 yd3) at an
off-site treatment/disposal facility. The only controls needed will be ICs to limit disturbance of the
backfill/cover soil and groundwater monitoring to confirm remedy protectiveness for the closed RCRA
units.
10.3.2 S- alternatives
Alternatives S-2 through S-4 are effective and permanent long-term remedial solutions. They all reduce
risks at the site to varying degrees. The controls needed are adequate and reliable.
Alternative S-2 is a containment remedy. The contaminated areas would be contained, not treated. The
controls needed include:
long-term maintenance,
ICs to limit disturbance of the cap,
inspections/maintenance of erosion controls, and
groundwater monitoring to confirm remedy protectiveness
Alternative S-3 will utilize a proven treatment technology to treat approximately 25,000 yd3 of mercury
waste and contaminated soil. In-situ solidification/stabilization is a permanent solution and reduces
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September 2017
mobility of contaminants. This technology has been used effectively on wastes at the site when the
facility was regulated under RCRA. The controls needed include:
ICs to limit disturbance of the stabilized areas; and
groundwater monitoring to confirm remedy protectiveness.
Alternative S-4 involves excavation and off-site treatment/disposal of approximately 25,000 yd3 of
contaminated material.
10.4 Reduction of toxicity, mobility, or volume through treatment
NCP §300.430(e)(9)(iii)(D) states: "Reduction of toxicity, mobility, or volume through treatment. The
degree to which alternatives employ recycling or treatment that reduces toxicity, mobility, or volume of
hazardous substances shall be assessed, including how treatment is used to address the principal threats
posed by the site. Factors that shall be considered, as appropriate, include the following:
(7) The treatment or recycling processes the alternatives employ and materials they will treat;
(2) The amount of hazardous substances, pollutants, or contaminants that will be destroyed, treated,
or recycled;
(5) The degree of expected reduction in toxicity, mobility, or volume of the waste due to treatment
or recycling and the specification of which reduction(s) are occurring;
(4) The degree to which the treatment is irreversible;
(5) The type and quantity of residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous substances
and their constituents; and
(6) The degree to which treatment reduces the inherent hazards posed by principal threats at the
site."
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Summary of Remedial Alternative Selection
September 2017
Table 98: Criteria 4 - Reduction of Toxicity, Mobility or Volume via Treatment Summary
Alternative
Treatment?
Volume
Volume
Reduction
Treated*
Disposed*
of TMV?
Overall Site Alternatives
A-l No Action
No
No
Capping with Limited Excavation, Off-site
3 Disposal, and ICs/ECs
No
_
34,600
TMV
same as A-2a except for WWTS treated with
A-2b
LTTD
Yes
TMV
23,700
10,900
A ^ Combination of Capping and Excavation, On-
site Disposal and ICs/ECs
No
_
39,100
TM
4 Combination of Capping and Excavation, Off-
site Disposal, and ICs/ECs
No
_
39,100
TMV
A-5 Excavation, On-site Disposal, and ICs/ECs
No
50,100
TM
A-6 Excavation, Off-site Disposal, and ICs/ECs
No
50,100
TMV
Soil Beneath Retort Pad and Mercury Cell Building Pad Al
tematives
1 /I;...
S-l No Action
No
No
^ Capping with Vertical Impermeable Barrier
Installation and ICs
No
_
_
TM
S-3 In-Situ Stabilization, Capping and ICs
Yes
25,000
25,000
TM
S-4 Excavation, Off-site Treatment and Disposal
Yes
25,000
25,000
TMV
Notes:
* volume units are cubic yards
Green background indicates that the alternative meets the criteria of that column
Red background indicates that the alternative does not meet the criteria or has the highest costs.
ECs = Engineering Controls
ICs = Institutional Controls
LTTD = low temperature thermal desorption
TMV = toxicity, mobility, volume
WWTS = Waste Water Treatment Solids
10.4.1 A- alternatives
The only A- alternative that includes treatment is alternative A-2b. The remainder of the A- alternatives,
except for A-l, reduce toxicity, mobility and/or volume through capping and/or on-site containment in a
TSCA disposal unit or off-site containment in an EPA-approved landfill.
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September 2017
Aternative A-2a does not include treatment but would reduce toxicity, mobility and volume at the site.
Off-site disposal would reduce the volume of contaminated material at the site by approximately 34,600
yd3. Capping would reduce mobility of COCs in soil by creating a barrier and preventing contact with
surface water and receptors.
Alternative A-2b would reduce toxicity and mobility through treatment. Approximately 23,700 yd3 of
WWTS would be treated via LTTD. Capping of approximately 2.4 acres would reduce mobility of
COCs in soil by creating a barrier and preventing contact with surface water and receptors.
Alternative A-3 does not involve treatment but would move the second highest volume of contaminated
material into an on-site disposal unit that complies with TSCA ARARs. Approximately 39,100 yd3 of
contaminated soil and sediment would be placed in a constructed TSCA disposal unit. This alternative
would reduce mobility of and exposure to the toxicity of COCs in soil by creating a barrier or isolating
material in an on-site TSCA disposal unit. These actions, once completed, would prevent contaminant
contact with surface water and receptors.
Alternative A-4 does not involve treatment but would reduce toxicity, mobility and volume at the site.
Off-site disposal of approximately 39,100 yd3 of contaminated soil and sediment would reduce the
volume of contaminated material on-site. Capping would reduce mobility of and exposure to COCs in
soil by creating a barrier and preventing contact with surface water and receptors.
Alternative A-5 does not involve treatment but would move the highest volume of contaminated
material into an on-site TSCA disposal unit. Approximately 50,100 yd3 of contaminated soil and
sediment would be placed in an on-site TSCA disposal unit. The disposal unit would reduce mobility of
and exposure to the toxicity of COCs in soil by creating a barrier or isolating material in an on-site
TSCA disposal unit. These actions, once completed, would prevent contaminant contact with surface
water and receptors.
Alternative A-6 does not involve treatment but would remove the highest volume of contaminated
material from the site. Approximately 50,100 yd3 of contaminated soils and sediments would be
removed from the site and disposed of in an EPA-approved off-site landfill. Capping in the L Areas
would reduce mobility of and exposure to COCs in soil by creating a barrier and preventing contact with
surface water and receptors.
10.4.2 S- alternatives
Alternatives S-3 and S-4 are the only S- alternatives that include treatment. Alternative S-2 would
reduce mobility via containment. Alternative S-3 would reduce toxicity and mobility via treatment using
ISS. Alternative S-4 would reduce toxicity, mobility and volume through excavation and off-site
treatment. However, treatment may not be possible if the waste includes concentrations of both mercury
and PCBs at levels that require treatment. Facilities currently cannot treat RCRA hazardous waste that
also has TSCA PCB waste at concentrations greater than 50 mg/kg.
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Summary of Remedial Alternative Selection
September 2017
10.5 Short-Term Effectiveness
NCP §300.430(e)(9)(iii)(E) states: "Short-term effectiveness. The short-term impacts of alternatives shall
be assessed considering the following:
(7) Short-term risks that might be posed to the community during implementation of an alternative;
(2) Potential impacts on workers during remedial action and the effectiveness and reliability of
protective measures;
(3) Potential environmental impacts of the remedial action and the effectiveness and reliability of
mitigative measures during implementation; and
(4) Time until protection is achieved."
Table 99: Criteria 5 - Short-term Effectiveness Summary
Alternative
Short-Term Effectiveness
Overall Site Alternatives
A-l No Action
not effective; no negative short-term effects
A Capping with Limited Excavation, Off-
site Disposal, and ICs/ECs
short-term impacts to ecological receptors. Short-term risk
to public during transportation to disposal facilities
same as A-2a except for WWTS treated
with LTTD
short-term impacts to ecological receptors. Short-term risk
to public during transportation to disposal facilities
A ^ Combination of Capping and Excavation,
On-site Disposal and ICs/ECs
minimal risk to worker; short term impacts to ecological
receptors.
A 4 Combination of Capping and Excavation,
Off-site Disposal, and ICs/ECs
short-term impacts to ecological receptors. Short-term risk
to public during transportation to disposal facilities
Excavation, On-site Disposal, and
ICs/ECs
minimal risk to worker; short-term impacts to ecological
receptors.
Excavation, Off-site Disposal, and
A"6 ICs/ECs
short-term impacts to ecological receptors. Short-term risk
to public during transportation to disposal facilities
Soil Beneath Retort Pad and Mercury Cell Buildin
g Pad Alternatives ' IS
S-l No Action
not effective; no negative short-term effects
Capping with Vertical Impermeable
Barrier Installation and ICs
minimal risk to worker; short-term impacts to ecological
receptors.
S-3 In-Situ Stabilization, Capping and ICs
minimal risk to worker; short-term impacts to ecological
receptors.
4 Excavation, Off-site Treatment and
Disposal
short-term impacts to ecological receptors. Short-term risk
to public during transportation to disposal facilities
Notes:
Green background indicates that the alternative meets the criteria of that column
Yellow background indicates that the alternative meets the criteria of that column, but not as well as alternatives with
green background
Red background indicates that the alternative does not meet the criteria.
ECs = Engineering Controls
ICs = Institutional Controls
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10.5.1 A- alternatives
Alternative A-l does not provide short-term protectiveness. The other A- alternatives provide short-term
effectiveness as discussed below.
Alternative A-2 is an effective short-term remedial solution. Capping and excavation provide immediate
risk reduction. Minimal risk to workers would be expected during construction activities. Localized,
short-term impacts on the ecological community would be limited to the Wooded Bottomland Area and
would be mitigated through restoring and revegetating to initiate habitat recovery. Risk to workers
would be managed through safe work practices and appropriate personal protective equipment (PPE).
Air monitoring would be required during earthmoving activities, and dust would be controlled through
dust suppression practices. Short-term risk of releases and public exposure during transportation of
contaminated material over long distances to disposal sites is limited to the relatively small
volume of material excavated.
Alternative A-3 is an effective short-term remedial solution. Capping and excavation provide immediate
risk reduction. Minimal risk to workers would be expected during construction activities. Localized,
short-term impacts on the ecological community would be limited to the Wooded Bottomland Area and
would be mitigated through restoring and revegetating to initiate habitat recovery. Risk to workers
would be managed through safe work practices and appropriate PPE. Air monitoring would be required
during earthmoving activities, and dust would be controlled through dust suppression practices.
Alternative A-4 is an effective short-term remedial solution. Capping and excavation provide immediate
risk reduction. Minimal risk to workers would be expected during construction activities. Localized,
short-term impacts on the ecological community would be limited to the Wooded Bottomland Area and
would be mitigated through restoring and revegetating to initiate habitat recovery. Risk to workers
would be managed through safe work practices and appropriate PPE. Air monitoring would be required
during earthmoving activities, and dust would be controlled through dust suppression practices.
Transportation of contaminated material over long distances to disposal sites increases short-term risk of
releases and public exposure.
Alternative A-5 is an effective short-term remedial solution. Excavation provides immediate risk
reduction. Minimal risk to workers would be expected during construction activities. Localized, short-
term impacts on the ecological community would be limited to the Wooded Bottomland Area and would
be mitigated through restoring and revegetating to initiate habitat recovery. Risk to workers would be
managed through safe work practices and appropriate PPE. Air monitoring would be required during
earthmoving activities, and dust would be controlled through dust suppression practices.
Alternative A-6 is an effective short-term remedial solution. Excavation provides immediate risk
reduction. Minimal risk to workers would be expected during construction activities. Localized, short-
term impacts on the ecological community would be limited to the Wooded Bottomland Area and would
be mitigated through restoring and revegetating to initiate habitat recovery. Risk to workers would be
managed through safe work practices and appropriate PPE. Air monitoring would be required during
earthmoving activities, and dust would be controlled through dust suppression practices. Transportation
of contaminated material over long distances to disposal sites increases short-term risk of releases and
public exposure.
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10.5.2 S- alternatives
Alternative S-l does not provide short-term protectiveness. The other S- alternatives provide short-term
effectiveness and risks as explained below.
Alternative S-2 is an effective short term remedial solution. Capping provides immediate risk reduction.
Minimal risk to workers would be expected during construction activities. Risk to workers would be
managed through safe work practices and appropriate PPE. Air monitoring would be required during
earthmoving activities, and dust would be controlled through dust suppression practices.
Alternative S-3 is an effective short term remedial solution. ISS provides immediate risk reduction.
Minimal risk to workers would be expected during construction activities. Risk to workers would be
managed through safe work practices and appropriate PPE. Air monitoring would be required during
implementation activities, and dust would be controlled through dust suppression practices.
Alternative S-4 is an effective short-term remedial solution; however, potential for exposure to waste
material and physical hazards are acknowledged. Potential risk to workers would be expected during
construction activities due to the potential for direct contact and inhalation of air borne particles. This
risk would be managed through safe work practices and appropriate PPE. Air monitoring would be
required during earthmoving activities, and dust would be controlled through dust suppression practices.
Transportation of contaminated soils over long distances to disposal sites increases short-term risk of
releases and public exposure.
10.6 Implementability
NCP §300.430(e)(9)(iii)(F) states: "Implementability. The ease or difficulty of implementing the
alternatives shall be assessed by considering the following types of factors as appropriate:
(7) Technical feasibility, including technical difficulties and unknowns associated with the
construction and operation of a technology, the reliability of the technology, ease of undertaking
additional remedial actions, and the ability to monitor the effectiveness of the remedy.
(2) Administrative feasibility, including activities needed to coordinate with other offices and
agencies and the ability and time required to obtain any necessary approvals and permits from
other agencies (for off-site actions);
(J) Availability of services and materials, including the availability of adequate off-site treatment,
storage capacity, and disposal capacity and services; the availability of necessary equipment and
specialists, and provisions to ensure any necessary additional resources; the availability of
services and materials; and availability of prospective technologies.
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Table 100: Criteria 6 - Implementability Summary
Alternative
Implementability
Overall Site Alternatives
A-l No Action
Yes
Capping with Limited Excavation, Off-site Disposal, and
ICs/ECs
Yes
A-2b same as A-2a except for WWTS treated with LTTD
Yes
Combination of Capping and Excavation, On-site Disposal and
ICs/ECs
Yes
Combination of Capping and Excavation, Off-site Disposal, and
ICs/ECs
Yes
A-5 Excavation, On-site Disposal, and ICs/ECs
Yes
A-6 Excavation, Off-site Disposal, and ICs/ECs
Yes
Soil Beneath Retort Pad and Mercury Cell Building Pad Alternatives
S-l No Action
Yes
S-2 Capping with Vertical Impermeable Barrier Installation and ICs
Yes
S-3 In-Situ Stabilization, Capping and ICs
Yes
S-4 Excavation, Off-site Treatment and Disposal
Difficult
Notes:
Green background indicates that the alternative meets the criteria of that column
Red background indicates that the alternative does not meet the criteria.
ECs = Engineering Controls
ICs = Institutional Controls
10.6.1 A- alternatives
Alternative A-l is "No Action". Therefore, it is the easiest to implement.
Alternative A-2a is the 2nd easiest to implement. This alternative includes excavation and off-site
disposal of the lowest volume of wastes compared to the other alternatives. It includes long-term
monitoring plus inspections and maintenance of ECs. Access roads and staging areas would need to be
constructed to implement work. Implementation materials and equipment are readily available and
techniques are commonly applied. Long-haul distances to an off-site EPA-approved landfill would be
anticipated. Time to complete implementation is estimated at approximately 12 months, assuming
continuous 24-hour/7 days per week operation and limited downtime.
Alternative A-2b is the most difficult to implement. WWTS will be treated by LTTD so that the treated
residual can be beneficially reused on-site. This alternative includes long-term monitoring plus
inspections and maintenance of ECs. Access roads and staging areas would need to be constructed to
implement work. Implementation materials and equipment are readily available and techniques are
commonly applied. Long-haul distances to an off-site EPA-approved landfill would be anticipated. Time
to complete implementation is estimated at approximately 12 months, assuming continuous 24-
hour/7 days per week operation and limited downtime.
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Alternative A-3 implementation is straightforward and includes long-term monitoring plus inspections
and maintenance of on-site TSCA disposal unit and RCRA units, in addition to and ECs. Access roads
and staging areas would need to be constructed to implement work. Implementation materials and
equipment are readily available and techniques are commonly applied. Time to complete
implementation is estimated at approximately 18 to 24 months.
Alternative A-4 implementation is straightforward and includes long-term monitoring plus inspections
and maintenance of ECs. Access roads and staging areas would need to be constructed to implement
work. Implementation materials and equipment are readily available and techniques are commonly
applied. Long-haul distances to an off-site EPA-approved landfill would be anticipated. Time to
complete implementation is estimated at approximately 12 months.
Alternative A-5 implementation is straightforward and includes long-term monitoring plus inspections
and maintenance of the on-site TSCA disposal unit and RCRA units, in addition to ECs. Access roads
and staging areas would need to be constructed to implement work. Implementation materials and
equipment are readily available and techniques are commonly applied. Time to complete
implementation is estimated at approximately 18 to 24 months.
Alternative A-6 implementation is straightforward and includes long-term monitoring plus inspections
and maintenance of ECs. Access roads and staging areas would need to be constructed to implement
work. Implementation materials and equipment are readily available and techniques are commonly
applied. Long-haul distances to an off-site EPA-approved treatment/disposal facility would be
anticipated. Time to complete implementation is estimated at approximately 12 months.
10.6.2 S- alternatives
Alternative S-l is "No Action". Therefore, it is the easiest to implement.
Alternative S-2 implementation is straightforward and includes long-term monitoring plus inspections
and maintenance. Access roads and staging areas would need to be constructed to implement work.
Implementation materials and equipment are readily available and techniques are commonly applied.
Time to complete implementation is estimated at approximately 6 to 12 months.
Alternative S-3 implementation is straightforward using conventional equipment and stabilization
agents. Access roads and staging areas would need to be constructed to implement work.
Implementation materials and equipment are readily available and techniques are commonly applied.
Time to complete implementation is estimated at approximately 6 to 12 months.
Alternative S-4 is the most difficult to implement. Implementation is difficult because of extensive
excavation/shoring required to excavate down to the Peedee Formation (10 to 15 feet), extremely long-
haul distances, and the limited availability of treatment facilities that will incinerate/retort soils that
contain both PCBs and mercury. Waste treatment and disposal facilities may reject the excavated
material if PCB concentrations are greater than 50 mg/kg, so that off-site treatment and disposal is not
available. Time to complete implementation may require up to 7 to 8 years due to the limited throughput
capacity of the identified retort facility.
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10.7 Costs
NCP §300.430(e)(9)(iii)(G) states: "Cost. The types of costs that shall be assessed include the following:
(7) Capital costs, including both direct and indirect costs;
(2) Annual operation and maintenance costs; and
(5) Net present value of capital and O&M costs."
Table 101: Criteria 7 - Cost Summary
Alternative
Estimated Costs
Capital
Annual
O&M
Total
Net Present
Worth*
Overall Site Alternatives
A-l No Action
$0
$0
$0
$0
A j Combination of Capping and Excavation, On-
site Disposal and ICs/ECs
$12,122,700
$36,500
$13,300,000
$12,600,000
A-5 Excavation, On-site Disposal, and ICs/ECs
$12,851,800
$31,500
$14,000,000
$13,300,000
^ 2a Capping with Limited Excavation, Off-site
Disposal, and ICs/ECs
$18,647,700
$31,500
$19,700,000
$19,000,000
. .. same as A-2a except for WWTS treated with
A-2b , __
LTTD
$20,180,300
$31,500
$21,300,000
$20,600,000
A 4 Combination of Capping and Excavation, Off-
site Disposal, and ICs/ECs
$20,453,700
$31,500
$21,600,000
$20,900,000
A-6 Excavation, Off-site Disposal, and ICs/ECs
$25,000,000
$29,000
$25,900,000
$25,400,000
Soil Beneath Retort Pad and Mercury Cell Building Pa
S-l No Action
d Alternatives
$0
*
$0
$0
g 2 Capping with Vertical Impermeable Barrier
Installation and ICs
$1,300,000
*
$1,300,000
N/A
S-3 In-Situ Stabilization, Capping and ICs
$2,900,000
*
$2,900,000
N/A
S-4 Excavation, Off-site Treatment and Disposal
$56,000,000
*
$56,000,000
. N/A
Notes:
* A discount rate of 7.0% was used in calculating Net Present Worth
** Annual O&M costs are included in the A- alternatives
Estimated costs are considered to be -30% to +50% in accuracy
ECs = Engineering Controls
ICs = Institutional Controls
LTTD = low temperature thermal destruction
O&M = operation and maintenance
Alternatives A-l and S-l, No Action, are the least expensive alternatives. As shown in Table 101, the
Total Present worth costs range from $0 to $25.4 million for the A- alternatives and $0 to $56 million
for the S- alternatives. In order of least expensive to most expensive the A- alternatives are: A-l, A-3,
A-5, A-2a, A-2b, A-4 and A-6. Similarly, the order for the S- alternatives are S-l, S-2, S-3 and S-4.
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10.8 State Acceptance
NCP §300.430(e)(9)(iii)(H) states: "State acceptance. Assessment of state concerns may not be
completed until comments on the RI/FS are received but may be discussed, to the extent possible, in the
proposed plan issued for public comment. The state concerns that shall be assessed include the
following:
(/) The state's position and key concerns related to the preferred alternative and other alternatives;
and
(2) State comments on ARARs or the proposed use of waivers."
NCDEQ has been actively involved with the site and has reviewed and provided comments on draft
documents throughout removal and remedial processes. Their comments resulted in a revision of the FS
during the public comment period of the Proposed Plan. NCDEQ submitted ARARs which are included
in this ROD. Their comments on the draft ROD have been incorporated into this revised version.
NCDEQ concurs with all alternatives except for A-l and S-l (no action).
10.9 Community Acceptance
NCP §300.430(e)(9)(iii)(I) states: "Community acceptance. This assessment includes determining which
components of the alternatives interested persons in the community support, have reservations about, or
oppose. This assessment may not be completed until comments on the proposed plan are received."
Community members did not submit or voice comments on the Proposed Plan. A transcript of the
Proposed Plan public meeting is included in APPENDIX B.
10.10 Comparative Analysis Summary
10.10.1 A- alternatives
The seven remedial overall site alternatives were compared relative to the CERCLA criteria. All
alternatives except Alternative A-l meet the threshold criteria of protecting human health and
environment and compliance with ARARs. Therefore, the No Action alternative is rejected. The
remaining alternatives are effective in the short and long term and are implementable using standard
construction equipment.
Total costs range from approximately $13,300,000 for Alternative A-3 with a combination of capping
and excavation with on-site disposal, to $25,900,000 for Alternative A-6 with the largest excavation
remedial footprint and off-site disposal. Both alternatives A-3 and A-5 include long-term maintenance
for the on-site TSCA disposal unit, previously-closed RCRA units, and installed caps; ICs; site security;
and long-term monitoring. The difference between these alternatives is that A-3 includes capping in
some additional upland process with discrete PCB samples above the site industrial worker exposure
goals of 11 mg/kg for total PCBs and within the TSCA level (below 50 mg/kg) for capping. Capping is
suitable for these areas, provides equivalent protectiveness, meets threshold criteria, is cost effective,
and does not impose a burden of additional monitoring because long-term monitoring is included in both
A-3 and A-5 for the on-site TSCA disposal unit.
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EPA's preferred overall site remedial alternative is Alternative A-3. This alternative is protective of
human health and the environment, is implementable using standard equipment, reduces mobility and
exposure to the toxicity of the COCs, and is effective both in the short and long term. The on-site TSCA
disposal unit also avoids drawbacks associated with some of the other alternatives, particularly those
resulting from hauling excavated materials over long distances. Transportation of contaminated soils
long distances to disposal sites increases risk of releases and public exposure. Truck traffic hauling
contaminated materials would be significantly increased in the local community. Therefore, on-site
disposal is also a more sustainable approach to the remedial issues represented by this site.
10.10.2 S- alternatives
The four alternatives for the soil associated with the former Cell Building and Retort pads were
compared relative to the CERCLA criteria. The No Action alternative (S-l) is rejected because it does
not meet the threshold criteria of protecting human health and environment and compliance with
ARARs.
Both Alternatives S-2 (Capping with Vertical Impermeable Barrier Installation and ICs) and S-3 (ISS,
Capping, and ICs) meet the threshold criteria. Both are effective in the short and long term, minimize
risk to workers during construction, and are implementable using standard equipment. Alternative S-3
offers the advantage of treatment and reduces mobility, with a slight increase in volume to accommodate
the solidification/stabilization agents, plus the thickness of the cap over the ISS areas. Alternative S-2
has the disadvantage of long-term monitoring of water levels inside the vertical barrier so that water
does not infiltrate the cap and accumulate such that hydraulic pressure increases.
Alternative S-4 (Excavation and Off-site Treatment and Disposal) may or may not comply with ARARs,
depending on the concentrations of PCBs in the excavated material and the ability of a treatment facility
to accept waste with PCB concentrations above TSCA regulated concentrations of 50 mg/kg if
encountered.
Alternative S-4 would be effective in the long term, but there is a higher potential for risk to workers
through dermal contact and inhalation. Toxicity and mobility would be reduced through treatment in this
alternative. Transportation of contaminated soils over long distances to disposal sites increases the
potential for short-term risk of releases and public exposure. Implementation is more difficult with
Alternative S-4 compared to Alternatives S-2 and S-3 due to the extensive shoring of the excavation
area, long haul distances, limited availability of approved and capable treatment and disposal facilities,
potential for rejection of excavated material for treatment if PCB concentration are greater than 50
mg/kg, the need to contain the material for extensive periods in a staging area, and long treatment times
(7 to 8 years). Cost is approximately 50 and 25 times more than Alternatives S-2 and S-3, respectively,
with no substantial increase in protection or reduction in risk.
Therefore, the recommended alternative for the soils associated with the Retort and Cell Building pads is
Alternative S-3 (ISS, Capping, and ICs). This alternative is protective of human health and the
environment, is effective both in the short and long term with no short-term exposure resulting from
hauling excavated materials over long distances and exposure to workers, is implementable using
standard equipment, and reduces mobility of constituents through treatment. It also meets EPA's
preference for treatment. In addition, Alternative S-3 lacks the many disadvantages associated with
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Alternative S-4. Although it is slightly higher in cost compared to Alternative S-2, it does offer the
advantage of treatment of the soils within the remedial footprint.
11.0 PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by
a site wherever practicable (NCP §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. In general,
the priority for treatment for PTW is placed on source materials considered to be liquid, highly toxic or
highly mobile, which generally cannot be contained in a reliable manner or would present a significant
risk to human health or the environment should exposure occur. There may be situations where the same
treatment remedy will be selected for both PTWs and low level threat wastes.
Despite limited sampling, available information indicates that significant volumes of elemental mercury,
a highly toxic material is present under the former Mercury Cell Building and Retort pads. Soil samples,
observations on site, and operational history indicate the presence of soil that is heavily contaminated
with elemental mercury. Puddles of elemental mercury on the floor in the former Mercury Cell Building
triggered the first removal action. Elemental mercury has been observed in cracks and fissures in the
concrete pad, prior to and following the removal of the building. The general understanding at this time
is that elemental mercury and sorbed mercury is likely present within the concrete pad and beneath the
pad within the underlying soils.
For these reasons, these areas are considered a source of contamination and as principal threat wastes.
These areas were carved out into the S- alternatives. The S-alternatives included options for no action,
containment, treatment, and off-site disposal/treatment. The selected alternative, ISS, is a treatment
technology that will solidify the mercury in place to prevent direct exposure and migration, thus
satisfying the statutory preference for treatment.
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12.0 SELECTED REMEDY
12.1 Summary of the Rationale for the Selected Remedy
Based on the information available at this time, EPA and NCDEQ believe that the Selected Remedy
combination satisfies the following statutory requirements of CERCLA Section 121(b) and Section
121(d): 1) protects human health and the environment; 2) complies with ARARs; 3) is cost effective; 4)
utilizes permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable; and 5) satisfies the preference for treatment as a principal element. The
selected remedy is the combination of remedial alternatives A-3 and S-3. The selected remedy meets the
Threshold CERCLA evaluation criteria; it is protective of human health and the environment and
complies with identified ARARs, although a waiver under TSCA at 40 CFR 761.75(c)(4) is necessary.
The remedy reduces mobility of and exposure to COCs and the ISS in Alternative S-3 meets EPA's
preference for treatment which reduces the toxicity and mobility of mercury waste and contaminated soil
that are considered PTW. Both A-3 and S-3 are effective in the short and long term and are cost
effective. There is no short-term exposure resulting from hauling excavated materials over long
distances or worker exposure.
12.2 Description of the Selected Remedy
The remedial action selected in this ROD addresses contamination that poses unacceptable risks to
human health and ecological receptors at the site. The contaminated media that poses unacceptable risks
include soil, sediment, surface water, as well as mercury waste and Wastewater Treatment Solids
(WWTS).
The selected remedy includes the following primary components:
Treatment of mercury waste and contaminated soil, considered to be principal threat waste
(PTW), located beneath the former mercury cell building and former retort pad via In-Situ
Stabilization (ISS)
Capping of the areas treated by ISS with a cover that meets RCRA Subtitle C landfill final cover
ARARs
Excavation of approximately 15,400 yd3 of contaminated soil and sediment
Capping approximately 1.7 acres of contaminated soil with a geosynthetic liner and vegetative
cover
Construction, operation, closure, maintenance and monitoring of an on-site disposal unit that
meets TSCA chemical waste landfill ARARs in 40 CFR § 761.75
Closure of the underground storm water conveyance system by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout
Disposal of stockpiled WWTS, solids removed from the storm water conveyance system, and
excavated contaminated soil and sediment that are not RCRA hazardous wastes in the
constructed on-site TSCA disposal unit
Treatment and/or disposal of RCRA hazardous wastes including soil that is considered RCRA
characteristic waste or contains RCRA listed waste, if generated, at an off-site permitted RCRA
treatment/disposal facility
Decommissioning of the storm water treatment system and restoration of the site to natural
drainage following completion of remedial action
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Disposal or recycling of demolition debris from the storm water treatment system and other
potentially dismantled structures. Disposition will be determined based on testing of the debris to
determine if it is RCRA hazardous wastes.
Monitoring and maintenance of the closed RCRA units (former surface impoundments) in
accordance with RCRA ARARs for post-closure care of a hazardous waste surface impoundment
Groundwater monitoring in accordance with ARARs to confirm TSCA disposal unit and closed
RCRA units' integrity
ECs in the form of fencing, warning signs and erosion control measures to control sedimentation
from stormwater runoff
ICs in the form of a restrictive covenant and/or Notice of Contaminated Site in accordance with
North Carolina statute
FYRs
The areas at the site that will be excavated, treated or capped are shaded in pink on Figure 46. The
remedial footprint shown in this figure may be expanded during remedial design and/or remedial action
to include adjacent areas. The remediation footprint consists of 13 areas which are described in Table 88
on page 161.
Figure 46: Remedial Footprint
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12.2.1 Wastes/Soils Beneath the Former Mercury Cell Building and Retort Pads
Areas F and G, described in Table 88 and illustrated on Figure 44, are areas considered to contain
mercury wastes. These areas correspond to the former retort and mercury cell building areas,
respectively. The selected remedy for these areas is alternative S-3.
This alternative treats wastes and soils under and around the concrete pads plus an approximate 10-foot
buffer beyond the pad edge with ISS. Soil outside the buffer zone in AreaF will be capped. Together,
ISS and capping protects industrial/construction workers through solidification/stabilization of soil with
mercury and/or PCB concentrations that exceed cleanup levels protective of the industrial or
construction worker in accordance with the RAOs in these areas. It also protects the Wooded
Bottomland Area by preventing contact of Upland Process Area soil with surface runoff and the
potential migration of soil into the Wooded Bottomland Area. The purpose of the ISS is to treat and
isolate the mercury waste and contaminated soils through encapsulation. Historically, these soils have
not served as a source of mercury or PCBs to groundwater. This alternative would serve as an added
measure so that they do not become a source in the future.
ISS
The selected remedy consists of ISS of the mercury waste and contaminated soil under and around the
former Retort Area and Mercury Cell Building pads in Areas F and G, respectively. The footprint of the
both ISS areas will be capped to minimize infiltration and potential for leaching of contaminants. ISS
reagents such as portland cement or lime/pozzolans (e.g., fly ash and cement kiln dust) or other agents
will be selected to reduce the leachability of COCs through encapsulation, binding, and/or limiting the
hydraulic conductivity of the final solidified matrix. A treatability study will be performed during the
Remedial Design (RD) to develop a suitable mix design to achieve post-solidification leachability goals
and establish parameters for field performance testing (e.g., compressive strength, hydraulic
conductivity, and /or wet/dry cycle durability). Various mix agents, such as sulfides and activated
carbon, will be evaluated during the treatability study to select the optimum mixing agent.
During field implementation, the ISS agents will be injected into the subsurface environment and mixed
with the soil using augers or other soil mixing equipment. The outside clean perimeter of the ISS area
may be augured first to act as a vertical barrier and avoid migration of COCs during implementation.
Performance sampling will be conducted at a pre-specified frequency, determined during the RD, with
samples collected from various depth intervals during mixing. The individual samples will be visually
examined to confirm mix homogeneity and then composited into cylinders representing the depth range
of the aliquots. The cylinders will be cured and analyzed per the performance testing plan.
The cell pit in Area G will be drained and the collected stormwater will be managed through the existing
stormwater collection and treatment system. The cell pit concrete will be pulverized and solidified as
part of the ISS area. The addition of solidification agents and physical mixing may increase the volume
of the treated soils, and this volume will be solidified and remain within the treated area footprint. The
potential increase in volume will be considered during the design phase. The total treated in-situ volume
is estimated to be 15,500 yd3.
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Capping
The selected remedy includes installing a cap over Areas F and G following ISS implementation. The
total cap area is estimated to be about 1.3 acres. The final cap area footprint will be confirmed during the
RD sampling and may be expanded from what is shown in Figure 44, as appropriate.
Capping will include placing a clay/geomembrane or equivalent cap system with a vegetated cover over
Areas F and G. Before cap placement, the area will be prepared by leveling in-ground structures. A
composite clay/geomembrane/cover soil or equivalent cap will be placed over the area to isolate the
waste and contaminated soil and will comply with RCRA ARARs for a hazardous waste landfill final
cover as well post-closure care requirements. The cap composition assumed for costing is a protective
underlayment of fill soil (compacted in place), a geosynthetic liner, a protective layer of fill soil on top
of the liner soil, plus up to six inches of topsoil to support revegetation. The actual cap composition and
soil layer thicknesses will be evaluated during the RD.
Cap placement activities will be conducted using standard construction equipment (e.g., backhoes,
bulldozers, graders, drill augers, etc.). Topographic survey and GPS instrumentation will be used to
confirm extents and final grades of cap emplacement.
Ancillary Activities
Site preparation activities will include the construction of:
access roads,
support zones, and
staging areas for personnel, equipment, and material.
Ancillary activities required to support construction activities include:
area access and preparation,
erosion control,
reagent material delivery and staging,
construction waste disposal,
stormwater management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
Ambient air will be monitored for dust during construction. Dust control measures will be implemented,
and include wetting roads, stockpiles, and staging areas. Real-time air monitoring will be performed
during construction activities to verify compliance with ARARs. Inspections and groundwater
monitoring will be required to verify system performance over time. ICs will be employed to prevent
risks to humans and damage to the selected remedy. ICs will consist of deed and land use restrictions.
12.2.2 Overall Site Remedy
Figure 39 on page 166 illustrates remedial actions for areas A through M (minus F and G, which were
discussed in Section 12.2.1), The rationale for selecting areas to be capped or excavated is based on the
size/local extent of detected contamination, the magnitude of PCB and mercury concentrations, and the
location/exposure risk.
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Remedial activities in the UPA include capping and excavation of soil areas with mercury and/or PCB
concentrations that exceed cleanup levels protective of the industrial or construction worker in
accordance with the RAOs. Capping and excavation in the UPA will also serve to protect the Wooded
Bottomland Area by preventing contact of UPA soil with surface runoff and the potential migration of
soil into the Wooded Bottomland Area.
Table 88 on page 161 describes each remedial area. Areas in the UPA to be capped include Areas A and
C. Areas A and C have detected concentrations of PCBs greater than 25 mg/kg but less than 50 mg/kg.
Area D contains concentrations of PCBs greater than 50 mg/kg, and will be excavated. Several isolated
areas (B, E, K, and M) with concentrations greater than the cleanup levels will be excavated because
long-term maintenance of a small cap in each of these areas would not be practical.
Similarly, the remedial areas in the Wooded Bottomlands Area (J Areas) will be excavated to limit long-
term maintenance. Excavated areas will be backfilled to approximately original grade and either
revegetated with native species or covered with an erosion control matting material and left for natural
revegetation by the WBA canopy. Capping and erosion control will occur in the L Areas, which are
located along the steep portion of the UNPA berm.
Capping
A cap will be applied over the larger contiguous Upland Process Areas that exceed the Aroclor
1254+Aroclor 1268 surface and subsurface soil cleanup level of 11 mg/kg in Areas A and C and the L
Areas along the berm of the Upland Non-Process Area impoundments. The anticipated extent of capping
is shown on Figure 39. The total cap area is estimated to be approximately 1.7 acres. The final cap area
footprint in some areas will be confirmed during the RD,
Capping includes placing a membrane-soil cap system with a vegetated cover over the remediation area.
The cap design will meet the North Carolina substantive requirements for a final cover on a RCRA
Subtitle D solid waste landfill as well as post-closure requirements that are determined by EPA to be
"relevant and appropriate" and identified as ARARs. Before cap placement, the area will be prepared by
clearing vegetation and leveling in-ground structures. A protective soil layer and geotextile membrane
will be placed over the area to isolate the PCB-containing soil. Another layer of protective soil will be
placed on top of the membrane, plus a layer of topsoil that will be vegetated for final restoration and
erosion control.
Material specifications will require fill soil to be clean. The cap composition assumed for costing is a
protective underlayment of fill soil (compacted in place), a geosynthetic liner, a protective layer of fill
soil on top of the liner soil, plus up to six inches of topsoil to support revegetation. The actual cap
composition and soil layer thicknesses will be evaluated during the RD and will comply with capping
ARARs.
Cap placement activities will be conducted using standard construction equipment (e.g., backhoes,
bulldozers, graders, etc.). Topographic survey and GPS instrumentation will be used to confirm extents
and final grades of cap emplacement.
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Summary of Remedial Alternative Selection
September 2017
Excavation
Contaminated soil above cleanup levels will be excavated in the Upland Process Areas B, D, and E and
Wooded Bottomland Areas J, K, and M. Areas B, D, and E exceed the Upland Process Area Aroclor
1254+Aroclor 1268 surface and subsurface soil cleanup level (11 mg/kg) protective of human health.
Areas J exceed the Wooded Bottomland Area Aroclor 1268 sediment cleanup level (47 mg/kg) and the
mercury sediment cleanup level (0.75 mg/kg) protective of ecological receptors. Areas K and M exceed
the Wooded Bottomland Area Aroclor 1254+Aroclor 1268 surface soil cleanup level (21 mg/kg)
protective of an adolescent trespasser/recreators.
The anticipated extent of excavation for this scenario is shown on Figure 39. The total in-place
excavation volume is estimated to be 15,400 yd3. The actual excavation footprints of the isolated areas
will be confirmed during the RD and further refined during the remedial action confirmation sampling.
Following excavation, clean backfill/topsoil will be placed in the areas to restore the ground surface to
approximately pre-excavation grades. The areas will be seeded/re-vegetated with a native species to
control erosion. Alternatively, the WBA areas may be covered with an erosion control matting material
and left for natural revegetation by the WBA canopy.
Removal activities will be conducted using standard construction equipment (e.g., backhoes, bulldozers)
equipped with GPS instrumentation to monitor removal progress and confirm that excavations meet the
established horizontal and vertical goals. Backfill will be placed to predetermined elevations using
conventional earthmoving equipment. Seeding and erosion controls will be implemented upon
verification that backfill design elevations have been met.
Where required, excavated soil will be stockpiled within a materials staging area for dewatering to meet
appropriate disposal requirements. Drying will be accomplished through a combination of gravity
dewatering and/or the addition of amendments (e.g., bed ash, fly ash, or portland cement). Drainage
from dewatering operations and potentially impacted stormwater will be managed through the existing
stormwater conveyance and treatment system. Excavated and dewatered materials will be transported
for disposal to an appropriate EPA-approved off-site permitted RCRA hazardous waste
treatment/disposal facility or placed in the on-site TSCA disposal unit.
Stormwater Conveyance System
The stormwater conveyance system (I Areas) will be closed by cleaning and/or sealing off and
solidifying the pipes/inlets in place using flowable grout. Solids, if removed during closure of the
system, will be dewatered and disposed either (1) in the on-site TSCA disposal unit, or (2) at an EPA-
approved off-site RCRA hazardous waste treatment/disposal facility.
Following completion of site-wide remedial activities active stormwater collection and management will
no longer be necessary. Therefore, the existing stormwater treatment system will be decommissioned
and the site returned to natural drainage. Long-term maintenance will include inspection and repair of
erosion controls designed to mitigate sedimentation during stormwater flow events.
WWTS
WWTS (Areas H) containing PCB concentration greater than 50 mg/kg are temporarily stockpiled at the
Mercury Cell Building pad and the SWDS. The selected remedy includes disposal of the WWTS in an
on-site disposal unit that meets TSCA chemical waste landfill requirements which are identified as
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LCP-HoItrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
ARARs. The total volume of the stockpiled soil on both the Mercury Cell Building pad and the SWDS
is approximately 23,700 yd3.
On-site TSCA Disposal Unit
Approximately 39,100 yd3 of contaminated soil, sediment, and solids will be disposed of in an on-site
newly constructed TSCA disposal unit. This unit will only contain site-related wastes. Because some of
the contaminated media include PCBs at concentrations greater than 50 mg/kg, the disposal unit will be
designed and constructed to meet the requirements of a TSCA chemical waste landfill as listed in 40
CFR §761.75 that are identified as ARARs. RCRA hazardous wastes, if generated during the remedial
action, will not be placed in the on-site TSCA disposal unit. They will be disposed of at an off-site EPA-
approved RCRA Subtitle C landfill.
Waiver and Design
40 CFR § 761.75(b)(3) requires that the bottom of a chemical waste landfill be at least 50 feet above the
historical high groundwater table. This distance is not naturally available at the site because there is
shallow groundwater. The 50 feet depth requirement is the only item in paragraph (b) which cannot be
met at the site. TSCA regulations at 40 CFR 761.75(c)(4) allows the Regional Administrator14 to waive
one or more of the requirements of paragraph (b) if evidence is submitted that indicates that operation of
the landfill will not present an unreasonable risk of injury to health or the environment from PCBs when
one or more of the requirements of paragraph (b) of this section are not met. This "no unreasonable risk
of injury to health or environment" standard is less stringent than the CERCLA Section 121(b) threshold
requirement that the selected remedy be protective of human health and the environment. The CERCLA
protectiveness requirement is addressed as part of the Comparative Analysis of Alternatives in Section
10.1.
To support the approval of a waiver under 40 CFR 761.75(c)(4) and meet the CERCLA threshold
protectiveness requirement, the TSCA disposal unit will be constructed using a dual-liner system. A
summary of the design specifications for a dual liner system includes the following:
The dual liner system would consist of a primary and secondary liners, each constructed with
synthetic membranes embedded between protective soil layers
Each membrane would have a permeability equal to or less than 1 x 10"7 cm/sec, be made of a
material that is chemically compatible with PCBs, and be at least 30 mils thick
Both membranes would be placed upon an adequate soil underlining and with a soil cover to
prevent excessive stress or rupture
Between the liner systems would be a porous leachate collection layer (e.g., coarse gravel) that
can be monitored (i.e., interstitial monitoring) for leak detection from the upper liner.
Installation of a dual liner system meeting the specifications will contain and confine the TSCA disposal
unit contents from direct contact with groundwater, equivalent to a 50-foot natural buffer. A 200-foot
thick dense clay confining unit (the Peedee formation) lies beneath the planned TSCA disposal unit
location and shallow surficial aquifer and further limits the potential for migration of PCBs.
Implementation of a dual-liner design along with the presence of the natural clay formation would
prevent releases of PCBs and thus the on-site TSCA disposal unit would not present an unreasonable
14 Approval authority for CERCLA remedies selected in RODs (which includes ARAR determinations and use of a waiver
where justified) has been delegated from the Regional Administrator to the Superfund Division Director.
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LCP-Holtrachem Superfiiiid Site
Summary of Remedial Alternative Selection
September 2017
risk of injury to health and the environment from PCBs under TSCA and also meet the CERCLA
protectiveness requirement.
A conceptual cross-section for the TSCA disposal unit is shown on Figure 40. The primary components
include the following:
TSCA disposal unit subgrade preparation including grading, compaction, and protection against
desiccation and cracking
A clay or equivalent underlayer to serve as a base for the sealing layer
A geosynthetic, clay, or equivalent sealing liner at the base of the TSCA disposal unit to provide
additional containment of the material inside the unit
A base geomembrane on top of the sealing liner to contain and prevent exfiltration of leachate
from the TSCA disposal unit
A second gravel drainage layer to collect leachate and to divert it to drains at the edge of the
TSCA disposal unit for discharge to the surface
An underdrain system between the bottom of the TSCA disposal unit liner system and
groundwater
Disposed waste surrounded by fill material (daily soil cover)
A clay cap or equivalent layer to contain the disposed material
A geomembrane sealing layer covering the TSCA disposal unit to stop infiltration of
precipitation into the disposed material
A permeable geocomposite drainage layer on top of the geomembrane to divert infiltration to
drains at the sides of the TSCA disposal unit
A drainage system at the edge of the cover to move stormwater runoff away from the TSCA
disposal unit
A layer of topsoil, seeded with vegetation for cover stabilization and to encourage
evapotranspiration of moisture that infiltrates the topsoil cover
Location
The TSCA disposal unit must meet buffer requirements identified in 15A NCAC 13B.0503(2)(f),
identified as ARARs. Because of the size of the property and a portion being within a 100-year flood
zone there are limited locations on the property where the TSCA disposal unit can be constructed. An
example conceptual TSCA disposal unit layout that would meet disposal volume requirements with a
footprint allowing for up to a 200-foot setback is shown in Figure 41. The selection of the TSCA
disposal unit location on the property will be based on the results of pre-design studies including but not
limited to geotechnical testing and evaluation, structural evaluation, hydrogeological evaluations,
surface hydraulics evaluation, material handling planning, and sequencing of remedial actions. The
potential to place the cell on top of the closed RCRA units or to avoid them will be carefully considered
in the RD, based upon the conclusions of the above evaluations. Should the TSCA disposal unit be
placed over these closed RCRA units, its design, construction, monitoring, and maintenance must be
compatible with the intended purpose of these RCRA units, their structural capacity/stability, and their
associated monitoring/maintenance requirements. The evaluation could result in a determination that the
on-site TSCA disposal unit cannot be located at the site due to concerns with structural integrity and
prevention of releases, such that another remedial alternative would have to selected through a
modification of the remedy.
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
Monitoring and Maintenance
It is possible that the TSCA disposal unit may extend over the retort and cell building pads where ISS
followed by placement of a soil cap has been implemented. Should the TSCA disposal unit be placed
over these areas, its design, construction, monitoring, and maintenance must be conducted in a manner
that will preserve the protectiveness and effectiveness of selected remedy for the retort and cell building
pads.
Long-term monitoring and maintenance for both the on-site TSCA disposal unit and closed-in-place
RCRA units will be conducted in accordance with TSCA and RCRA ARARs.
Ancillary Activities
Site preparation activities will include the construction of access roads, support zones, and staging areas
for personnel, equipment, and material. Clearing and installation of erosion controls would be required
for support and staging areas.
Ancillary activities required to support construction activities include:
cap/excavation area access and preparation,
erosion control,
backfill material delivery and staging,
excavated material staging and handling,
cover soil delivery and staging,
construction waste disposal,
cap placement verification,
waste soil transport and disposal,
stormwater management,
dust monitoring/control,
seeding/planting, and
restoration, as necessary.
Ambient air will be monitored for dust during construction. Dust control measures will be implemented,
and include wetting roads, stockpiles, and staging areas. Real-time air monitoring will be performed
during construction to verify compliance with ARARs.
Site-wide long-term maintenance and inspection will be required to evaluate backfill erosion and to
verify cap, TSCA disposal unit, and previously closed RCRA unit performance over time. Long-term
monitoring of groundwater will also be required to confirm TSCA disposal unit and closed RCRA unit
integrity and compliance with ARARs. Periodic maintenance will be carried out as needed to preserve or
restore the integrity of these systems. ICs and ECs will be employed to limit risks to human and
ecological receptors and protect the integrity of the remedy. ICs will consist of deed and land use
restrictions in a recorded a Notice and/or restrictive covenant. ECs will consist of warning signs and
fencing. The site is currently fenced along the west, south, and east property boundaries.
223
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
12.3 Summary of the Estimated Remedy Costs
The total estimated cost for the selected remedy is $13,300,000 for Alternative A-3 and $2,900,000 for
Alternative S-3. The combined total is $16,200,000. The estimate is based on the current 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 engineering design of the
remedial alternative. This is an order-of-magnitude engineering cost estimate that is expected to be
within +50 to -30 percent of the actual project cost.
12.3.1 Selected Remedy Alternative A-3
Costs for Alternative A-3 include the following:
Preparation of work plans and remedial design including remedial design sampling
Mobilization of equipment
Site preparation including access roads, clearing and grubbing, temporary offices,
decontamination pads, demarcation of remedial work zones, dust control, and turbidity curtain
along the Cape Fear River
Contractor site operations including utilities, dust control, storm water management, compaction
testing, and land surveying
Excavation of Areas B, D, E, J, K, and M; excavated material and stockpiled soil (H Areas) to be
direct-loaded into trucks for disposal in an on-site landfill
Construction of an on-site chemical waste landfill, consisting of the following:
o Landfill design and construction plan
o Mobilization of construction equipment
o Demolition of existing structures and footings within landfill footprint
o Grading and compacting landfill subgrade
o Access road construction
o Construction of landfill liner/bottom (groundwater underdrain, landfill liner, and leachate
collection system)
o Transfer of stockpiled soil (H Areas) and excavated material to the landfill
o Spreading of compact material inside landfill and daily cover
o Construction of landfill cap (install clay/membrane cap, geotextile drainage layer, topsoil,
and seed/mulch)
o Installation of a leachate/groundwater storage tank
Capping of Areas A and C with geomembrane/soil cap (a protective underlayment of fill soil
(compacted in place), a geosynthetic liner, a protective layer of fill soil on top of the liner soil,
plus up to six inches of topsoil to support revegetation).
Site restoration re-grading and seeding disturbed areas including:
o Upland Areas with topsoil, seed, and mulch
o Wooded Bottomland Areas with plantings
o Stream areas with geotextile riprap/gabion mattresses
Demobilization
Post-construction confirmation sampling
Labor, equipment, and materials for approximately 18 to 24 months of operations
A 30-year, long-term operations, maintenance, monitoring, and reporting program including:
o Annual inspections and maintenance
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Record of Decision Summary of Remedial Alternative Selection
LCP-Holtrachem Superfund Site September 2017
o Annual groundwater and surface water monitoring for mercury and PCBs
o Annual reports and five-year ROD review support
The total estimated cost for Alternative A-3 is approximately $13,300,000. The estimated costs are
presented in Table 102.
225
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Record of Decision
LCP-Holtrachem Superfund Site
Table 102: Alternative A-3 Cost Estimate Summary
Summary of Remedial Alternative Selection
September 2017
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226
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Record of Decision
LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
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? baa ad oanu |ti ^ M) vn li a ^ ami isd fa uuc&j ia be laid an earaaa ao^ m L to ansa imari ifae wa, b^fill ca i*u pi
X ^pitdwaal lab^TJI onBdaqoaoa uupodbscUill ^OPSaadldtHfua, gmt bu^
9 TfcD luminal an^im ¦inaiaa^aa a 1^ y^tfrad"aateid piia latailag)
IA duM-uil^lal^idlaya wife upis^dbiaamuon: 1 fLhau^ J ft if a^tmi dope -9(1 wdci ^tad)BBata ia waJndplumphcrtsdini
Pl^p d br: Fm $4)i*ZU 4
Onicdbr:ADB«rtt4ai4
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Record of Decision
LCP-HoItrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
12.3.2 Selected Remedy Alternative S-3
Costs for Alternative S-3 include the following:
Preparation of remedial design including remedial design sampling
Mobilization/demobilization of equipment
Areas F and G surface preparation
Cleaning and backfilling of cell pit (next to Area G)
In situ treatment of soil below the former pads at Areas F and G through ISS
Capping of the F and G areas (including the ISS footprints and the area surrounding the former
Retort Pad in Area F)
Restoration of disturbed areas
Site preparation, contractor operations, and long-term operations/maintenance are included in
Alternatives A-2 through A-6 and are not repeated for the S alternatives. The total estimated cost for
Alternative S-3 is approximately $2,900,000. The estimated costs are presented in Table 103.
228
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LCP-Holtrachem Superfimd Site
Summary of Remedial Alternative Selection
September 2017
Table 103: Alternative 5-3 Cost Estimate Summary
Ste; raJtrtduni
JUxiybK
Thr tytimirmlTO In-star solidfriitiorLCif Art tG (phis lO'b^Ta 3c«)«ndfcimer Retort Are i Ptd. risid* AniF. 1
Assune nn-phce vertictlmEdng afbenrmie Aement stay. C«p remiitdjer of An t F. 1
But Year: 3014
1
Qundily
1Mb
UttCwt
ratal Hun
tot'
Conuimiii/Htta
CAIIIAL COSTS
b thl
AMtioeblcojt fx F ft Oarttophmiag ntinobilntuii
Wiak Plxn
1
LS
$10,173
$10,300
l&b & Ddcb
1
LS
555J580
$55,700
Dfmcltim of Sttulmi
Ant 0 Demoliliftoct slib
30060
SF
$391
$117,500
Am CLotd& Hin^iait CaicxetE
lp60
CY
S3.49
e^oo
CcUptBw*
60
CY
$130.14
$7,800
Ana O subsurface denoltim
830
CY
$48.67
$41,400
Ant GLotddfc Thm^att Concrete
830
CY
$3.49
©JXO
IrtjlDaruiitim
$173,400
h- ffltt VIllftfdim/StiliLdicax
Soil An G
11^33
CY
$10432
$1,160,300
k$±ti«oiliEL2X2rigofpoat^xdj)Dstlatie stoiy qprac. ID ft. deep
Soil At* F (ptd tnt enfy)
4,400
CY
$10433
$158000
fortusoflmK^ofpciit)nlAadaii££lixy.qfffoc. lStdtcp
UibSiltadDnt
$1 £18 p00
C«pnc
Cip AttF
25JH 4
SF
$5.18
$139)500
Cap F and. &utu (iocluks ISS nee as plus F snb. socflarandittatp&d)
Cip Ae»5
30JM0
SF
$5.18
$155^00
SOdltoaalnM rnmparit* cap system.
UdCfjif
$285,3110
ilelUcAik
Site Restoration Am tF
35030
SF
$094
$33,500
Site Restoration An tG
30060
SF
$094
$38,300
IM»1 Rtttsrrtjcn
$si;n>o
SUBTOTAL
$2,195,200
CoautructiaiBwd
3%
$65,900
SUBTOTAL
$3 ^61,100
Ctatttogmcy
10%
$326,100
TOTAL COKSTRUCTION
$2,487^00
tttrfddUyStuty
Utah Plan .Bench Stmi>',»id Reporting
1
LS
$45 pOO
$45,000
FKOIESSiaHAI SERVICES
ftoje ct Muniment
3%
$49,700
ISS TfreirteMWy Stutfy
3%
$74,000
RemedklDesi^L
2%
$49,700
ftocuremetliS: Bands
0.5%
$13,400
Ganflmctiari Oversight
3%
$49,700
Hettti 4 Sifetyiegd
1%
$24,900
SUBTOTAL
$261000
Comnmicttiai ite
3%
J7JE0
Constiuctiai Uttacondrt Ikes
5%
$134360
SUBTOTAL
1393300
TOTJLL CAPITAL COSTS
¦W'I'Hm"
1
LS-Iuq> Sum ftnjpmeiby:FKM5j6/3014
CY- CUbic Ya& Oudodty: ADB MMD14
SF- Squm Ret Bsrised:EKM 3/183015
Aisuajrians:
1. Eftinue d com tit c ens ideredto be -30% to +50% iri *c cumy uri tie menu to b< c mpmtxre betsw on
2. Od^ is iopluiiaagdtindu timid* ilUnutiwc
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LCP-Holtrachem Superfimd Site
Summary of Remedial Alternative Selection
September 2017
12.4 Expected Outcome of the Selected Remedy
The expected outcome of the selected remedy is achievement of the RAOs described in Section 8.0.
Expected land use would be ecological habitat, with the option of industrial use in the Upland Areas.
The use will be limited by institutional controls that will prevent unacceptable land uses and protect the
integrity of the remedy which includes caps, maintenance of former RCRA units, and an on-site TSCA
disposal unit. Construction time frame is estimated at approximately 2 years. The completed remedy will
reduce risks to human and ecological receptors to levels provided for in the NCP (i.e. cancer risk of 10"5,
and non-cancer equal to or less than HQ of 1). The selected remedy will lower the risks by reducing the
concentrations of the soil, sediment and surface water contaminants to the cleanup levels in Table 104
and Table 105. Cleanup levels are based on ARARs, which provide minimum legal standards, and in the
absence of ARARs, risk-based concentrations.
Table 104: Upland Area Cleanup Levels
Site Area:
Upland Areas
Available Use:
Industrial
Controls to Ensure Restricted Use:
Deed Notice and/or Restrictive Covenant
Chemical of Concern
Cleanup Level
Basis for Cleanup Level
Risk at Cleanup Level
Surface Soil (0-1 foot)
Arodor 1268
11, mg/kg
Risk Assessment
Construction Worker
HI = 1
benzo(a)pyrene
3.1 mg/kg
Risk Assessment
Industrial Worker
cancer risk = lxlO'5
mercury
516 mg/kg
Risk Assessment
Industrial Worker
HI = 1
Subsurface Soil (1-10 feet)
Arodor 1254 + Arodor 1268
11, mg/kg
Risk Assessment
Construction Worker
HI = 1
mercury
926' mg/kg
Risk Assessment
Construction Worker
HI = 1
Notes:
These values are for both the Upland Process Area and Upland Non-Process Area.
HI = hazard index
mg/kg = miligram per kilogram (or parts per million)
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Summary of Remedial Alternative Selection
September 2017
Table 105: Wooded Bottomland Area Cleanup Levels
Site Area:
Wooded Bottomland Area
Available Use:
Ecological Habitat
Controls to Ensure Restricted Use:
Deed Notice and/or Restrictive Covenant
Chemical of Concern
Cleanup Level
Basis for Cleanup Level
Risk at Cleanup Level
Surface Soil (0-0.5 foot) - Ecological
2,3,7,8-TCDDTEQs (dioxins/furans)
8.54E-05: nig/kg
Risk Assessment
LOAEL risk to Carolina wren
HQ=0.90
2,3,7,8-TCDD TEQs (PCBs)
1.96E-04I mg/kg
Risk Assessment
LOAEL risk to Carolina wren
HQ = 0.10
mercury compounds
3: mg/kg
Risk Assessment
Ecological Receptor
HI = 1
Surface Soil (0-1 foot) - Human Health
2,3,7,8-TCDD TEQs (dioxins/furans + PCBs)
9.36E-04i mg/kg
Risk Assessment
Adolescent Trespasser/Recreator
cancer risk = lxlO"5
Aroclor 1254 + Aroclor 1268
21; mg/kg
Risk Assessment
Adolescent Trespasser/Recreator
HI = 1
Sediment (0-0.5foot) -Ecological
Aroclor 1268
47| mg/kg
Risk Assessment
LOAEL risk to green blue heron
HI =1
mercury
0.75 mg/kg
Risk Assessment
LOEC in amphibian and macroinvertebrate toxicity testing
Surface Water - Human Health
2,3,7,8-TCDD TEQs (dioxins/furans)
8.70E-06ing/L
Risk Assessment
Adolescent Trespasser/Recreator
cancer risk = lxlO"5
2,3,7,8-TCDD TEQs (PCBs)
9.50E-06lug/L
Risk Assessment
Adolescent Trespasser/Recreator
cancer risk = lxl0"5
Aroclor 1268
0.44| ng/L
Risk Assessment
Adolescent Trespasser/Recreator
HI = 1
Notes:
HI = hazard index
PCB = polychlorinated biphenyj
HQ.= hazard quotient
TCDD =total chlorinated dibenzo-p-dioxins
LOAEL = lowest observed adverse effects level
TEQ = Toxic Equivalent Quotient
LOEC = lowest observed effects concentration
lig/L = microgram perliter{orparts perbi 11 ion)
mg/kg = miligram per kilogram (or parts per.million)
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LCP-Holtrachem Superfund Site
Summary of Remedial Alternative Selection
September 2017
13.0 STATUTORY DETERMINATIONS
Under CERCLA §121 and the NCP, the lead agency must select remedies that are protective of human
health and the environment, comply with applicable or relevant and appropriate requirements (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
Selected remedy Alternative A-3 is protective of human health and the environment. Capping isolates
and prevents erosion and direct exposure of human and ecological receptors to COCs in soil. Excavation
and backfilling remove COC-impacted media and protect human and ecological receptors from potential
exposure to residual COCs in soil and sediment. Containment of excavated material in an on-site TSCA
disposal unit prevents its erosion and migration, and precludes further exposure to human and ecological
receptors. ICs control access and further limit exposure to humans.
Selected remedy Alternative S-3 is protective of human health and the environment. ISS treats the
mercury wastes and contaminated soil followed by installation of a RCRA cap to eliminate potential
future mobility and prevent erosion and potential exposure to COCs in soil to human and ecological
receptors. ICs control access and further limit exposure to humans.
ICs will be required as part of the selected remedy because contaminants will remain at levels above that
suited for unlimited use and unrestricted exposure in the capped areas as well as within the on-site
TSCA chemical waste landfill.
The following generally describes those ICs to be considered for implementation at the site to achieve
the bulleted performance objectives:
Prohibit residential or recreational land use at the site.
Prohibit any consumptive use of groundwater including but not limited to drinking water,
irrigation or industrial use.
Prohibit intrusive activities such as excavation in the contaminated media areas that remain.
Prevent interference with the integrity of any existing or future monitoring or remediation system
including capped areas and groundwater monitoring wells.
ICs placed on the property will include recording and environmental restrictive covenant (following the
State of North Carolina Declaration of Perpetual Land Use Restrictions process), which requires the
recordation of a survey plat map defining the boundaries of the site and/or a Notice of Contaminated
Site filed in Columbus County real property records in accordance with North Carolina General Statutes
(NCGSs) 143B-279.9 and 143B-279.10. A restrictive covenant may be executed by the property owner
and recorded that outline land and groundwater use restrictions including the prohibition of any
residential or recreational reuse of the property. The covenant would also prohibit interference with the
integrity of any existing or future monitoring or remediation system without prior EPA and NCDEQ
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September 2017
approval. Notice of the application of land and groundwater use restrictions to the site via the restrictive
covenant would be provided to the local regulatory agencies. The details for implementation of these ICs
will be provided in the Remedial Action Work Plan, which will be reviewed and approved by EPA and
NCDEQ.
Should any IC fail, EPA and NCDEQ will ensure that appropriate actions are taken to reestablish the
remedy's protectiveness and may initiate legal action to either compel action by the PRP or a third party
and/or to recover costs for remedying any discovered IC violations.
13.2 Compliance with ARARs
Section 121(d) of CERCLA and NCP §300.430(f)(l)(ii)(B) require that remedial actions (RA) at
CERCLA sites attain legally applicable or relevant and appropriate federal and more stringent state
environmental requirements, standards, criteria, and limitations which are collectively referred to as
"ARARs," unless an ARAR waiver under CERCLA section 121(d)(4) is justified. Applicable
requirements are those cleanup standards, standards of control, and other substantive requirements,
criteria, or limitations promulgated under Federal environmental or State environmental or facility siting
laws that specifically address a hazardous substance, pollutant, contaminant, RA, location, or other
circumstance found at a CERCLA site. Relevant and appropriate requirements, are those cleanup
standards, standards of control, and other substantive requirements, criteria, or limitations promulgated
under Federal environmental or State environmental or facility siting laws that, while not "applicable" to
a hazardous substance, pollutant, contaminant, RA, location, or other circumstance at a CERCLA site
address problems or situations sufficiently similar to those encountered at the CERCLA site that their
use is well-suited to the particular site.
Under CERCLA Section 121(e)(1), federal, state, or local permits are not required for the portion of any
removal or remedial action conducted entirely 'on-site' as defined in 40 CFR §300.5. See also 40 CFR
§300.400(e)(l) & (2). Also, CERCLA response actions must only comply with the "substantive
requirements," not the administrative requirements of a regulation or law. Administrative requirements
include permit applications, reporting, record keeping, inspections, and consultation with administrative
bodies. Although consultation with state and federal agencies responsible for issuing permits is not
required, it is often recommended for determining compliance with certain requirements such as those
typically identified as location-specific ARARs. See EPA, OSWER Directives No. 9234.1-01 and
9234.1-02, CERCLA Compliance with Other Laws Manual: Parts 1 and Part II (August 1988 and
1989).
In addition to ARARs, the lead and support agencies may, as appropriate, identify other advisories,
criteria, or guidance to be considered for a particular release that may be useful in developing Superfund
remedies. See 40 CFR §300.400(g)(3). The "to-be-considered" (TBC) category consists of advisories,
criteria, or guidance that were developed by EPA, other federal agencies, or states that may assist in
determining, for example health-based levels for a particular contaminant for which there are no ARARs
or the appropriate method for conducting an action. TBCs are not considered legally enforceable and,
therefore, are not considered to be applicable for a site but typically are evaluated along with Chemical-
specific ARARs as part of the risk assessment to determine protective cleanup levels. See EPA, OSWER
Directives No. 9234.1-01 and 9234.1-02, CERCLA Compliance with Other Laws Manual: Parts 1 and
Part II {August 1988 and 1989), Section 1.4.
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September 2017
For purposes of ease of identification, the EPA has created three categories of ARARs: Chemical-,
Location- and Action-Specific. Under 40 CFR §300.400(g)(5), the lead and support agencies shall
identify their specific ARARs for a particular site and notify each other in a timely manner as described
in 40 CFR §300.515(d).
Chemical-Specific ARARs/TBC Guidance
Chemical-specific ARARs are usually health or risk-based numerical values limiting the amount or
concentration of a chemical that may be found in, or discharged to, the environment such as
groundwater and surface water. The chemical-specific ARARs/TBC for the selected remedy to protect
surface water and groundwater are identified in Appendix A - ARARs.
Location-Specific ARARs/TBC Guidance
Location-specific requirements establish restrictions on permissible concentrations of hazardous
substances or establish requirements for how activities will be conducted because they are in special
locations (e.g., wetlands, floodplains, critical habitats, streams). The location-specific ARARs/TBC for
the selected remedy which includes requirements for actions in wetlands, floodplains and near aquatic
resources are identified in Appendix A - ARARs.
Action-Specific ARARs/TBC Guidance
Action-specific ARARs are usually technology-based or activity-based requirements or limitations that
control actions taken at hazardous waste sites. Action-specific requirements often include performance,
design and controls, or restrictions on particular kinds of activities related to management of hazardous
substances. Action-specific ARARs are triggered by the types of remedial activities and types of wastes
that are generated, stored, treated, disposed, emitted, discharged, or otherwise managed. Action-specific
ARARs for this site include TSCA requirements for construction, operation and closure/post-closure
(including monitoring) of a chemical waste landfill, TSCA requirements for management and cleanup
of PCB remediation wastes, general construction management requirements to control fugitive dust and
stormwater during land disturbing activities, and RCRA waste characterization, treatment, storage and
disposal requirements as well as RCRA landfill final cover requirements for capping contaminated areas
at the site and post-closure care requirements for the RCRA surface impoundments that have been
referred to the Superfund Program by NCDEQ. The action-specific ARARs for the selected remedy are
identified in Appendix A - ARARs.
Due to the site conditions with respect to depth to groundwater, a waiver of one of the TSCA chemical
waste landfill technical requirements at 40 CFR §761.75(b)(3) related to hydrologic conditions (so-
called 50ft. buffer between bottom of the landfill liner and historically high water table) identified as an
ARAR is required for the on-site TSCA disposal unit since groundwater is present at depths less than 50
ft. The waiver under the TSCA regulation 40 CFR §761.75(c)(4) requires that information has been
provided to EPA that demonstrates the placement and operation of the on-site TSCA disposal unit will
not present unreasonable risk of injury to health and the environmental from PCBs when one or more
technical requirements are not met. Based upon the use of a dual liner with a leachate collection layer,
the type and permeability of the liner materials, leak detection monitoring, as well as the clay formation
underlying much of the Uplands areas of the site, the EPA believes the waiver is appropriate and the on-
site TSCA disposal unit (as constructed with these additional specifications) will prevent groundwater
intrusion into the bottom of the landfill and potential releases of PCBs and therefore is protective of
human health and the environment under CERCLA.
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Summary of Remedial Alternative Selection
September 2017
13.3 Cost Effectiveness
The Selected Remedy is cost-effective and represents a reasonable value for the money 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 §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-compliant). 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 this remedial alternative was determined to be proportional to
its costs and hence this alternative represents a reasonable value for the money to be spent.
The estimated present worth cost of the selected remedy is $16.2 million. Alternative A-3 is the least
expensive of the A- alternatives. Although Alternative S-3 is $1.6 million more expensive than S-2, the
selected remedy provides for treatment whereas S-2 provides for containment. EPA believes that the
selected remedy's additional cost for stabilization provides a significant increase in protection of human
health and the environment and is cost-effective.
13.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a practicable manner at the site. Of those
alternatives that are protective of human health and the environment and comply with ARARs, EPA has
determined that the selected remedy provides the best balance of trade-offs in terms of the five balancing
criteria, while also considering the statutory preference for treatment as a principal element and bias
against off-site treatment and disposal and considering State and community acceptance. The on-site
TSCA disposal unit that will contain PCB waste and PCB contaminated soils is a permanent solution
that is long-term effective and protective of human health and the environment despite that there is no
treatment or resource recovery for that waste and soil.
13.5 Preference for Treatment as a Principal Element
CERCLA Section 121(b) establishes a preference for treatment as a principal element of a selected
remedy. The NCP establishes an expectation that EPA will use treatment to address the principal threats
posed by a site wherever practicable (NCP §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.
In general, the priority for treatment for PTW is placed on source materials considered to be liquid,
highly toxic or highly mobile, which generally cannot be contained in a reliable manner or would
present a significant risk to human health or the environment should exposure occur. As stated in the
preamble to the NCP (55 FR at 8703, March 8,1990 and in Superfund Publication 9380.3-06FS, "A
Guide to Principal Threat and Low Level Threat Wastes there may be situations where wastes
identified as constituting a PTW may be contained (e.g. isolated) rather than treated due to inherent
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September 2017
difficulties in treating the wastes. There may be situations where the same treatment remedy will be
selected for both PTWs and low level threat wastes.
Despite limited sampling, available information indicates that significant volumes of elemental mercury,
a highly toxic material is present under the former Mercury Cell Building and Retort pads. Soil samples,
observations on site, and operational history indicate the presence of soil that is heavily contaminated
with elemental mercury. Puddles of elemental mercury on the floor in the former Mercury Cell Building
triggered the first removal action. Elemental mercury has been observed in cracks and fissures in the
concrete pad, prior to arid following the removal of the building. The general understanding at this time
is that elemental mercury and sorbed mercury is likely present within the concrete pad and beneath the
pad within the underlying soils. For these reasons, these areas are considered a source of contamination
and as PTW.
The selected remedy treats the PTW beneath the former cell building and retort pad via stabilization to
prevent direct exposure and migration of contaminants. By utilizing treatment as a significant portion of
the remedy that reduces toxicity and mobility of hazardous substances, the statutory preference for
remedies that employ treatment as a principal element is satisfied.
13.6 Five-Year Review Requirements
Section 121(c) of CERCLA and NCP §300.430(f)(5)(iii)(C) provide the statutory and legal bases for
conducting five-year reviews. 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 will be conducted within five years after initiation of remedial action to ensure that the
remedy is, or will be, protective of human health and the environment.
14.0 DOCUMENTATION OF SIGNIFICANT CHANGES
After the Proposed Plan was published, AMECFW revised the FS during the public comment period
based on comments from NCDEQ. The modifications did not significantly change the alternatives but
included provided corrections/clarification of language in the FS. NCDEQ and EPA approved the
revised FS.
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Summary of Remedial Alternative Selection
September 2017
PART 3: RESPONSIVENESS SUMMARY
EPA did not receive any comments from the public regarding the Proposed Plan. Appendix B includes
the public meeting transcript.
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS TABLES
Table A-l: Chemical-Specific ARARs and TBCs
Table A-2: Location-Specific ARARs and TBCs
Table A-3: Action-Specific ARARs and TBCs
-------
Table A-l. Chemical-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Chemical-Specific ARARs
Action/Media
Requirements
Prerequisite
Citation(s)
Protection of surface
water
The concentration of toxic substances, either alone or in
combination with other wastes, in surface waters shall not
render waters injurious to aquatic life or wildlife, recreational
activities, public health, or impair waters for any designated
uses.
Fresh surface waters classified as Class C
waters which are protected for secondary
recreation, fishing, aquatic life including
propagation and survival, and wildlife -
relevant and appropriate
15A NCAC 02B.0208(a)
Standards for Toxic substances
Protection of surface
water
The concentration of toxic substances shall not result in
chronic toxicity. Any levels in excess of the chronic value shall
be considered to result in chronic toxicity. In the absence of
direct measurements of chronic toxicity, the concentration of
toxic substances shall not exceed the concentration specified
by the fraction of the lowest LC50 value that predicts a no
effect chronic level (as determined by the use of acceptable
acute/chronic ratios). If an acceptable acute/chronic ratio is
not available, then that toxic substance shall not exceed one-
one hundredth (0.01) of the lowest LC50 or if it is
affirmatively demonstrated that a toxic substance has a half-
life of less than 96 hours the maximum concentration shall
not exceed one-twentieth (0.05) of the lowest LC50.
1'5A NCAC 02B.0208(a)(l)
Aquatic Life Standards
Protection of surface
water
The concentration of toxic substances shall not exceed the
level necessary to protect human health through exposure
routes of fish (shellfish) tissue consumption, water
consumption, or other route identified as appropriate for the
water body.
Polychlorinated biphenyls (PCBs): 0.064 ng/l
Fresh surface waters classified as Class C
waters which are protected for secondary
recreation and fishing - relevant and
appropriate
ISA NCAC 02B.0208(a)(2),(B)(xii)
Human Health Standards
Protection of surface
water
The waters shall be suitable for aquatic life propagation and
maintenance of biological integrity, wildlife, secondary
recreation, and agriculture.
Sources of water pollution that preclude any of these uses on
either a short-term or long-term basis shall be considered to
be violating a water quality standard.
Fresh surface waters classified as Class C
waters which are protected for aquatic life
including propagation and survival, and
wildlife - relevant and appropriate
ISA NCAC 02B.0211(2)
Fresh surface standards for Class C
-------
Chemical-Specific ARARs
Action/Media
Requirements
Prerequisite
Citation(s)
Protection of surface
water
Numerical water quality standards (maximum permissible
levels) for the protection of aquatic life:
Mercury: 0.012 ug/l
Polychlorinated biphenyls (total of all PCBs and
congeners identified): 0.001 ug/l
Mercury and selenium water quality standards shall be based
upon measurement of the total recoverable metal.
Fresh surface waters classified as Class C
waters which are protected for aquatic life
including propagation and survival, and
wildlife - relevant and appropriate
15A NCAC 02B.0211(ll)(b)(vii) and
15A NCAC 02B.0211(16)
Aquatic Life Water Quality Criteria
ARAR = applicable or relevant and appropriate requirement
CFR = Code of Federal Regulation
EPA = U.S. Environmental Protection Agency
NCAC = North Carolina Administrative Code
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citatlon(s)
Aquatic Resources and Wetlands
Presence of Wetlands
Shall take action to minimize the destruction, loss or
degradation of wetlands and to preserve and enhance
beneficial values of wetlands.
Federal actions that involve potential impacts
to, or take place within, wetlands -TBC
Executive Order 11990
Section 1(a) Protection of
Wetlands
Shall avoid undertaking construction located in wetlands
unless: (1) there is no practicable alternative to such
construction, and (2) that the proposed action includes all
practicable measures to minimize harm to wetlands which may
result from such use.
Executive Order 11990,
Section 2(a) Protection of
Wetlands
Location encompassing
aquatic ecosystem as defined
in 40 CFR 230.3(c)
No discharge of dredged or fill material into an aquatic
ecosystem is permitted if there is a practicable alternative that
would have less adverse impact on the aquatic ecosystem or if
will cause or contribute significant degradation of the waters
of the US.
Action that involves the discharge of dredged
or fill material into waters of the United
States, including jurisdictional wetlands -
applicable
40 CFR § 230.10(a) and (c)
Clean Water Act Regulations -
Section 404(b) Guidelines
Except as provided in § 404(b)(2), no discharge of dredged or
fill material shall be permitted unless appropriate and
practicable steps in accordance with Subpart H at 40 CFR
230.70 etseq. have been taken that will minimize potential
adverse impacts of the discharge on the aquatic ecosystem
40 CFR § 230.10(d)
Clean Water Act Regulations -
Section 404(b) Guidelines
Must comply with the substantive requirements of the NWP
38 General Conditions, as appropriate, any regional or case-
specific conditions recommended by the Corps District
Engineer, after consultation.
On-site CERCLA action conducted by Federal
agency that involves the discharge of dredged
or fill material into waters of the United
States, including jurisdictional wetlands - TBC
Nation Wide Permit (38)
CleanuD of Hazardous and
Toxic Waste
33 CFR § 323.3(b)
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
Presence of wetlands or
other waters influenced by
wetlands
The following activities for which Section 404 permits are not
required pursuant to Section 404(f)(1) of the Clean Water Act
and.which are not recaptured into the permitting process
pursuant to Section 404(f)(2) are deemed to be in compliance
with wetland standards in 15A NCAC 2B .0231:
construction of temporary sediment control
measures or best management practices as required
by the NC Sediment and Erosion Control Program on
a construction site, provided that the temporary
sediment control measures or best management
practices are restored to natural grade and stabilized
within two months of completion of the project and
native woody vegetation is reestablished during the
next appropriate planting season and maintained;
Activities within wetlands, as defined by 6.S.
143-212(6), that comply with the most current
versions of the federal regulations to
implement Section 404 (f) (US Environmental
Protection Agency and US Army Corps of
Engineers including 40 CFR 232.3) and the
Sedimentation Pollution Control Act, G.S.
113A, Article 4 - applicable
15A NCAC 02B.0230(a)(5)
Presence of wetlands or
other waters influenced by
wetlands
The following standards shall be used to assure the
maintenance or enhancement of the existing uses of wetlands
identified in Paragraph (a) of this Rule:
Liquids, fill or other solids or dissolved gases may not
be present in amounts which may cause adverse
impacts on existing wetland uses;
Floating or submerged debris, oil, deleterious
substances, or other material may not be present in
amounts which may cause adverse impacts on
existing wetland uses;
Materials producing color, odor, taste or
unsightliness may not be present in amounts which
may cause adverse impacts on existing wetland uses;
Activities within, wetlands as defined by G.S.
143-212(6) -applicable
15A NCAC 02B.0231(b)(l)-(3)
2
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Table A-2. Location-Specific ARARs and TBCs
for LCP Hoitrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Cltatlon(s)
Presence of wetlands or
other waters influenced by
wetlands con't
The following standards shall be used to assure the
maintenance or enhancement of the existing uses of wetlands
identified in Paragraph (a) of this Rule:
Concentrations or combinations of substances which
are toxic or harmful to human, animal or plant life
may not be present in amounts which individually or
cumulatively may cause adverse impacts on existing
wetland uses;
Hydrological conditions necessary to support the
biological and physical characteristics naturally
present in wetlands shall be protected to prevent
adverse impacts on:
(A) Water currents, erosion or sedimentation patterns;
(B) Natural water temperature variations;
(C) The chemical, nutrient and dissolved oxygen regime of
the wetland;
(D) The movement of aquatic fauna;
(E) The pH of the wetland; and
(F) Water levels or elevations.
The populations of wetland flora and fauna shall be
maintained to protect biological integrity as defined
at 15A NCAC 2B .0202.
Activities within, wetlands as defined by G.S.
143-212(6) - applicable
15A NCAC 02B.0231(b)(4)-(6)
3
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
Determination that surface
water uses are not removed
or degraded
Determining that existing uses are not removed or degraded
by a discharge to classified surface waters for an activity
which:
(1) has no practical alternative under the criteria outlined in
Paragraph (f) of this Rule;
(2) will minimize adverse impacts to the surface waters
based on consideration of existing topography, vegetation,
fish and wildlife resources, and hydrological conditions under
the criteria outlined in Paragraph (g) of this Rule;
(3) does not result in the degradation of groundwaters or
surface waters;
(4) does not result in cumulative impacts, based upon past or
reasonably anticipated future impacts, that cause or will
cause a violation of downstream water quality standards;
(5) provides for protection of downstream water quality
standards through the use of on-site stormwater control
measures; and
(6) provides for replacement of existing uses through
mitigation as described at Subparagraphs (h)(1) of this Rule.
NOTE: Determination will be made by EPA in consultation
with NCDEQ and the USACE, as appropriate and
documented in CERCLA Remedial Design or Remedial
Action Work Plan.
Discharge to classified surface waters -
applicable
15A NCAC 02H .0506(b)
4
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Determination that wetlands
uses are not removed or
degraded
The Director shall issue a certification upon determining that
sufficient existing uses are not removed or degraded by a
discharge to Class WL wetlands as defined at 15A NCAC 2B
.0101(c)(8), for an activity which:
(1) has no practical alternative as described in Paragraph (f)
of this Rule1, or impacts less than three acres of Class WL
wetlands;
(2) will minimize adverse impacts to the wetland based on
consideration of existing topography, vegetation, fish and
wildlife resources, and hydrological conditions under the
criteria outlined in Paragraph (g) of this Rule; or impacts less
than one acre of wetland within 150 feet (including less than
1/3 acre of wetland within 50 feet), of the mean high water
line or normal water level of any perennial or intermittent
water body as shown by the most recently published version
of the United State Geological Survey 1:24,000 (7.5 minute)
scale topographical map or other site specific data;
(3) does not result in the degradation of groundwaters or
surface waters;
(4) does not result in cumulative impacts, based upon past or
reasonably anticipated future impacts, that cause or will
cause a violation of downstream water quality standards;
(5) provides protection for downstream water quality
standards through the use of on-site stormwater control
measures; and
(6) provides for replacement of existing uses through
wetland mitigation under U.S. Army Corps of Engineers
requirements or as described in Subparagraph (h)(l)-(8) of
this Rule.
NOTE: Certification is an administrative requirement.
Determination will be made by EPA in consultation with
NCDEQand the USACE, as appropriate and documented in
CERCLA Remedial Design or Remedial Action Work Plan to
the extent that the wetlands on the site or portions of the
wetlands on the site are Class WL.
Discharge to Class WL wetlands, as defined at
15A NCAC 2B .0101(c)(8) - applicable
15A NCAC 02H .0506(c)
5
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Cltation(s)
Wetlands Mitigation
Replacement or mitigation of unavoidable losses of existing
uses shall be reviewed in accordance with the guidelines
provided in paragraphs (1) through (10) of this rule.
NOTE: Permits are not required per CERCLA Section
121(e)(1); however consultation with other permitting
agencies (such as the USACE) is necessary in order to
demonstrate compliance with mitigation requirements.
Discharge to Class WL wetlands as defined at
15A NCAC 2B .0101(c)(8) - applicable
15A NCAC 02H .0506(h)
Discharges to Isolated
Wetlands and Isolated
Waters
The following are exempt from this Section and shall not be
considered to remove existing uses of the isolated wetland or
isolated surface waters:
(1) Activities that are described in 15A NCAC 02B .0230
ACTIVITIES DEEMED TO COMPLY WITH WETLANDS
STANDARDS;
(2) Discharges to isolated, man-made ponds or isolated
ditches except for those wetlands or waters constructed for
compensatory mitigation or for on-site stormwater
management;
(3) Discharges of treated effluent into isolated wetlands and
isolated classified surface waters resulting from activities
which receive NPDES Permits or State Non-Discharge
Permits;
(4) Discharges for water dependent structures as defined in
15A NCAC 02B .0202(67);
NOTE: Permits are not required per CERCLA Section
121(e)(1); however compliance with the substantive
NPDES requirements for discharge is required by CERCLA
Section 121(d).
Discharges2 resulting from activities on
isolated wetlands and isolated classified
surface waters which require a determination
by NCDEQ and the USACE - applicable
15A NCAC 02H .1300(d)
1 Ref. 15A NCAC 02H .0506(f) - A lack of practical alternatives may be shown by demonstrating that, considering the potential for a reduction in size, configuration or density of
the proposed activity and all alternative designs the basic project purpose cannot be practically accomplished in a manner which would avoid or result in less adverse impact to
surface waters or wetlands.
2 For the purpose of this Section, discharge shall be the deposition of dredged or fill material including but not limited to fill, earth, construction debris and soil.
6
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citatlon(s)
Mitigation on ephemeral
channels
Mitigation provider shall provide a delineation of the
watershed draining to the ephemeral channel. The entire area
proposed for mitigation shall be within the contributing
drainage area to the ephemeral channel. The ephemeral
channel shall be directly connected to an intermittent or
perennial stream and contiguous with the rest of the
mitigation site protected under a perpetual conservation
easement. The area of the mitigation site on ephemeral
channels shall comprise no more than 25 percent of the total
area of buffer mitigation. The proposal shall meet all
applicable requirements of Paragraph (n) of this Rule for
restoration or enhancement. The proposal shall meet all
applicable requirements of Subparagraph (o)(4) or (o)(5) of this
Rule for preservation.
Activities affecting riparian buffers for
ephemeral channels3 - relevant and
appropriate
15A NCAC 02B ,0295(o)(7)
MITIGATION PROGRAM
REQUIREMENTS FOR
PROTECTION AND
MAINTENANCE OF RIPARIAN
BUFFERS
Restoration and
enhancement on ditches
The width of the restored or enhanced area shall not be less
than 30 feet and shall not exceed 50 feet for crediting
purposes. The applicant or mitigation provider shall provide a
delineation of the watershed draining to the ditch. The
watershed draining to the ditch shall be at least four times
larger than the restored or enhanced area along the ditch. The
perpetual conservation easement shall include the ditch and
the confluence of the ditch with the intermittent or perennial
stream, and provide language that prohibits future
maintenance of the ditch. The proposal shall meet all
applicable requirements of Paragraph (n) of this Rule for
restoration or enhancement.
Activities affecting riparian buffers for ditches4
- relevant and appropriate
15A NCAC 02B ,0295(o)(8)
B An "ephemeral channel" is defined as a natural channel exhibiting discernible banks within a topographic crenulation (V-shaped contour lines) indicative of natural drainage on
the 1:24,000 scale (7.5 minute) quadrangle topographic map prepared by the U.S. Geologic Survey
4 A "ditch" is defined as a man-made channel other than a modified natural stream that was constructed for drainage purposes.
7
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegeiwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citatlon(s)
Restoration and
enhancement on ditches
To be used for mitigation, a ditch shall meet all of the following
criteria:
(A) be directly connected with and draining towards an
intermittent or perennial stream;
(B) be contiguous with the rest of the mitigation site
protected under a perpetual conservation easement;
(C) stormwater runoff from overland flow shall drain towards
the ditch;
(D) be between one and three feet in depth; and
(E) the entire length of the ditch shall have been in place
prior to the effective date of the applicable buffer rule.
Activities affecting riparian buffers for ditches
- relevant and appropriate
15A NCAC02B .0295(o)(8)
Ftoodplalns
Presence of Floodplains
designated as such on a map5
Shall take action to reduce the risk of flood loss, to minimize
the impact of floods on human safety, health and welfare, and
to restore and preserve the natural and beneficial values
served by floodplains.
Federal actions that involve potential impacts
to, or take place within, floodplains - TBC
Executive Order 11988
Section 1. Floodplain
Management
Shall consider alternatives to avoid, to the extent possible,
adverse effects and incompatible development in the
floodplain. Design or modify its action in order to minimize
potential harm to or within the floodplain
Executive Order 11988
Section 2(a)(2) Floodplain
Management
Where possible, an agency shall use natural systems,
ecosystem processes, and nature-based approaches when
developing alternatives for consideration.
Executive Order 13690
Section 2(c)
Presence of floodplain
designated as such on a map
The Agency shall design or modify its actions so as to
minimize6 harm to or within the floodplain.
Federal actions affecting or affected by
Floodplain as defined in 44 CFR § 9.4 -
relevant and appropriate
44 CFR § 9.11(b)(1)
Mitigation
5 Under 44 CFR § 9.7 Determination of proposed action's location, Paragraph (c) Floodplain determination. One should consult the FEMA Flood Insurance Rate Map (FIRM), the
Flood Boundary Floodway Map (FBFM) and the Flood Insurance Study (FIS) to determine if the Agency proposed action is within the base floodplain.
6 Minimize means to reduce to smallest amount or degree possible. See 44 CFR § 9.4 Definitions.
8
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Cltatlon(s)
The Agency shall restore and preserve natural and beneficial
floodplain values.
44 CFR § 9.11(b)(3)
Mitigation
The Agency shall minimize:
Potential harm to lives and the investment at risk
from base flood, or in the case of critical actions7
from the 500-year flood;
Potential adverse impacts that action may have on
floodplain values.
44 CFR §9.11(c)(l) and (3)
Minimization provisions
Wildlife, Threatened or Endangered Species
Presence of Migratory birds
listed in 50 CFR § 10.13
No person may take, possess, import, export, transport, sell,
purchase, barter, or offer for sale, purchase, or barter, any
migratory bird, or the parts, nests, or eggs of such bird except
as may be permitted under the terms of a valid permit issued
pursuant to the provisions of this part and part IB of this
chapter, or as permitted by regulations in this part, or part 20
of this subchapter (the hunting regulations).
Action that have potential impacts on, or is
likely to result in a 'take' (as defined in 50 CFR
§ 10.12) of migratory birds - applicable
Migratory Bird Treaty Act, 16
U.S.C. §703(a)
50 CFR §21.11
7 See 44 CFR § 9.4 Definitions, Critical action. Critical actions include, but are not limited to, those which create or extend the useful life of structures or facilities such as those
that produce, use or store highly volatile, flammable, explosive, toxic or water-reactive materials.
9
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
Presence of federally
Endangered and Threatened
species listed in 50 CFR
17.11(h) - or critical habitat
of such species listed in SO
CFR § 17.95
Federal agency shall, in consultation with and with the
assistance of the Secretary, insure that any action authorized,
funded, or carried out by such agency is not likely to jeopardize
the continued existence of any endangered species or
threatened species or result in the destruction or adverse
modification of habitat of such species which is determined by
the Secretary of Interior, after consultation as appropriate with
affected States, to be critical, unless such agency has been
granted an exemption for such action by the Committee
pursuant to subsection (h) of this section.
NOTE: Despite that consultation may be considered an
administrative requirement, it should be performed to
ensure activities are in compliance with substantive
provisions of the Endangered Species Act and regulations.
Agency action that may jeopardize listed
wildlife species, or destroy or adversely modify
critical habitat - applicable
16 U.S.C. §1536 (a)(2)
-or Section 7(a)(2) of the
Endangered Species Act of
1973
Presence of Threatened and
Endangered Wildlife listed in
50 CFR § 17.11(h)
Except as provided in the rule, it is unlawful to take threatened
or endangered wildlife in the United States.
NOTE: Under 50 CFR § 10.12 Definitions the term Take
means to pursue, hunt, shoot, wound, kill, trap, capture, or
collect, or attempt to pursue, hunt, shoot, wound, kill,
trap, capture, or collect.
Action that may jeopardize American alligator,
green turtle, and/or loggerhead turtle -
applicable
50 CFR § 17.21(c)
50 CFR § 17.31(a)
50 CFR § 17.42(a)and (b)
Siting ofTSCA Landfill
Siting of a TSCA chemical
waste landfill
The landfill shall be located in thick, relatively impermeable
formations such as large area clay pans. Where this is not
possible, the soil shall have a high clay and silt content with the
following parameters:
In place soil thickness, 4-ft or compacted soil liner
thickness, 3-ft;
Permeability (cm sec), equal to or less than 1 x 10-7;
Percent soil passing No. 200 sieve > 30;
Liquid limit, > 30; and
Plasticity index > 15.
Construction of a TSCA chemical waste landfill
- applicable
40 CFR § 761.75(b)(1)
10
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
Hydrologic conditions
The bottom of the landfill shall be above the historical high
groundwater table as provided below. Floodplains, shorelands,
and groundwater recharge areas shall be avoided. There shall
be no hydraulic connection between the site and standing or
flowing surface water.
The site shall have monitoring wells and leachate collection.
The bottom of the landfill liner system or natural in-place soil
barrier shall be at least 50 ft. from the historical high water
table.
NOTE: The 50ft. depth from the bottom liner to
groundwater requirement is being waived under 40 CFR
5761.75(c)(4) and the justification is provided in the ROD.
Construction of a TSCA chemical waste landfill
- applicable
40 CFR § 761.75(b)(3)
Waiver of a TSCA chemical
waste landfill technical
requirement
An owner or operator of a chemical waste landfill may submit
evidence to the Regional Administrator that operation of the
landfill will not present an unreasonable risk of injury to health
or the environment from PCBs when one or more of the
requirements of paragraph (b) of this section are not met. On
the basis of such evidence and any other available information,
the Regional Administrator may in his discretion find that one
or more of the requirements of paragraph (b) of this section is
not necessary to protect against such a risk and may waive the
requirements in any approval for that landfill. Any finding and
waiver under this paragraph will be stated in writing and
included as part of the approval.
NOTE: Waiver of any technical requirement shall be made
as part of the CERCLA ROD process. The CERCLA remedy
protectiveness standard applies in addition to the TSCA
standard.
Construction of a TSCA chemical waste landfill
- applicable
40 CFR § 761.75(c)(4)
Floodplain
Shall provide surface water diversion dikes around the
perimeter of the landfill site with a minimum height equal to
two feet above the 100-year floodwater elevation.
Construction of a TSCA chemical waste landfill
(below the 100-year floodwater elevation) -
applicable
40 CFR § 761.75(b)(4)(i)
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
Shall provide diversion structures capable of diverting all
surface water runoff from a 24-hour, 25-year storm.
Construction of a TSCA chemical waste landfill
(above the 100-year floodwater elevation) -
applicable
40 CFR § 761.75(b)(4)(ii)
Topography
The landfill site shall be located in an area of low to moderate
relief to minimize erosion and to help prevent landslides or
slumping.
40 CFR § 761.75(b)(5)
Siting of a Disposal Site (i.e.,
solid waste landfill)
A site located in a floodplain shall not restrict the flow of the
100 -year flood, reduce the temporary water storage capacity
of the floodplain, or result in washout of solid wastes so as to
pose a hazard to human life, wildlife, or land or water
resources.
Construction of a disposal site (except a land
clearing and debris landfill) located in North
Carolina - relevant and appropriate
15A NCAC 13B ,0503(l)(a)
A disposal site shall meet the following buffer requirements:
(i) A 50-foot minimum buffer between all property
lines and disposal areas;
(ii) A 500-foot minimum buffer between private
dwellings and wells and disposal areas; and
(iii) A 50-foot minimum buffer between streams
and rivers and disposal areas.
Construction of a disposal site (except a land
clearing and debris landfill) located in North
Carolina - relevant and appropriate
15A NCAC 13B .0503(2)(f)
Buffer Requirements
ARAR = applicable or relevant and appropriate requirement
CFR = 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
NCDEQ = North Carolina Department of Environmental Quality
N.C.G.S. = North Carolina General Statutes
NPDES = National Pollutant Discharge Elimination System
PCB = polychlorinated biphenyl
POTW = Publicly Owned treatment Works
TBC = to be considered
TSCA = Toxic Substances Control Act of 1976
USACE = U.S. Army Corps of Engineers
U.S.C. = United States Code
12
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Table A-2. Location-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
13
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
General Construction Standards - All land-disturbing activities (I.e., excavation, 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-157(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-157(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 15A NCAC 4B.0106
would be included in the CERCLA Remedial Design or
Remedial Action Work Plan
N.C.G.S. Ch,113A-157(5)
Shall take all reasonable measures to protect all public and
private property from damage caused by such activities.
Land-disturbing activity (as defined in
N.C.G.S. Ch. X13A-52) of more than 1 acre of
land-applicable
15A NCAC 4B.0105
Managing storm water
runoff from land-
disturbing activities
Erosion and sedimentation control plan must address the
following basic control objectives:
(1) Identify areas subject to severe erosion, and off-site
areas especially vulnerable to damage from erosion
and sedimentation.
(2) Limit the size of the area exposed at any one time.
(3) Limit exposure to the shortest feasible time.
(4) Control surface water run-off originating upgrade of
exposed areas
(5) Plan and conduct land-disturbing activity so as to
prevent off-site sedimentation damage.
(6) Include measures to control velocity of storm water
runoff to the point of discharge.
Land-disturbing activity (as defined in
N.C.G.S. Ch. 113A-52) of more than 1 acre of
land - applicable
15A NCAC 4B.0106
1
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Table A-3. Action-Specific ARARs and TBCs
for LCP Hoitrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Managing storm water
runoff from land-
disturbing activities con't
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
15A NCAC 4B.0108
Shall conduct activity so that the post-construction velocity of
the 10 year storm run-off in the receiving watercourse to the
discharge point does not exceed the parameters provided in
this Rule.
15A NCAC 4B.0109
Shall install and maintain all temporary and permanent erosion
and sedimentation control measures.
15A NCAC 4B.0113
Erosion control near
High Quality Water
zones
Erosion and sedimentation control measures, structures, and
devices within High Quality Water (HQW) zones shall be
planned, designed and constructed to provide protection from
the runoff of the 25 year storm.
Land-disturbing activity (as defined in
N.C.G.S. Ch. 113A-52) of more than 1 acre of
land in High Quality Water (HQW) zones -
applicable
15A NCAC 4B.0124(b)
Provisions for ground cover sufficient to restrain erosion must
be provided for any portion of the land-disturbing activity with
15 working days or 60 calendar days following completion of
the construction or development, which period is shorter.
15A NCAC 4B.0124(e)
Implement good construction management techniques, best
management practices for sediment and erosion controls, and
storm water management measures in accordance with 15A
NCAC 02H .1008 to ensure storm water discharges are in
compliance.
Development activity (otherwise requiring a
stormwater permit) within one mjle of and
draining to waters classified as High Quality
Waters (HQW) - relevant and appropriate
15A NCAC 02H .1006, NC General
Permit CNCG 0100000
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
Discharge of Wastewater from De-watering of stockpiled soil and sediments
General duty to mitigate
for discharge
Take all reasonable steps to minimize or prevent any discharge
or sludge use or disposal in violation of effluent standards which
has a reasonable likelihood of adversely affecting human health
or the environment.
Discharge of pollutants to surface waters of
the State - applicable
40 CFR § 122.41(d)
2
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Operation and
maintenance of
treatment system
Properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are
installed or used to achieve compliance with the effluent
standards. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance
procedures.
Discharge of pollutants to surface waters of
the State - applicable
40 CFR § 122.41(e)
Technology-based
treatment requirements
for wastewater
discharge
To the extent that EPA promulgated effluent limitations are
inapplicable, develop on a case-by-case Best Professional
Judgment (BPJ) basis under Section 402(a)(1)(B) of the CWA,
technology based effluent limitations by applying the factors
listed in section 125.3(d) and shall consider:
The appropriate technology for this category or class
of point sources, based upon all available information;
and
Any unique factors relating to the discharger.
Discharge of pollutants to surface waters
from other than a POTW - applicable
40 CFR § 125.3(c)(2)
15A NCAC 02B. 0406(e)
Effluent Limitations
Water quality-based
effluent limits for
wastewater discharge
Must develop water quality based effluent limits that ensure
that:
The level of water quality to be achieved by limits on
point source(s) established under 40 CFR §
122.44(d)(l)(vii) is derived from, and complies with all
applicable water quality standards; and
Effluent limits developed to protect narrative or
numeric water quality criteria are consistent with the
assumptions and any available waste load allocation
for the discharge prepared by the State and approved
by EPA pursuant to 40 CFR § 130.7.
Discharge of pollutants to surface waters that
causes, or has reasonable potential to cause,
or contributes to an instream excursion
above a narrative or numeric criteria within a
State water quality standard - applicable
40 CFR § 122.44(d)(l)(vii)
3
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltatlon(s)
Monitoring
requirements for
discharges
In addition to 40 CFR § 122.48 (a) and (b) and to assure
compliance with effluent limitations requirements to monitor,
one must monitor, as appropriate, according to the substantive
requirements provided in 40 CFR § 122.44(i)(l)(i) through (iv).
NOTE: Monitoring location and frequency will be conducted
in accordance with CERCLA Remedial Action Work Plan.
Discharge of pollutants to surface waters -
applicable
40 CFR § 122.44(i)(l)
15A NCAC 02B.0505
Monitoring Requirements
40 CFR § 122.44(i)(2)
All effluent limitations, standards and prohibitions shall be
established for each outfall or discharge point, except as
provided under 40 CFR § 122.44(k).
All effluent limitations, standards and prohibitions, including
those necessary to achieve water quality standards, shall unless
impracticable be stated as:
Maximum daily and average monthly discharge limitations for
all discharges
Continuous discharge of pollutants to surface
waters - applicable
Disposal of PCB
contaminated
precipitation,
condensation, and
leachate
May be disposed in a chemical waste landfill which complies
with 40 CFR § 761.75 if:
e disposal does not violate 40 CFR § 268.32(a) or §
268.42(a)(1);
liquids do not exceed 500 ppm PCB and are not an ignitable
waste as described in 40 CFR § 761.75(b)(8)(iii).
PCB liquids at concentrations 2 50 ppm and £
500 ppm from incidental sources such as
precipitation, condensation, leachate or load
separation and associated with PCB Articles
or non-liquid PCB wastes - applicable
40 CFR § 761.60(a)(3)
40 CFR § 761.60(a)(3)(i) and (ii)
Discharge of PCB
contaminated water
For water discharged to a treatment works (as defined in 40 CFR
§ 503.9 (aa), or to navigable waters, meet standard of < 3 ppb
PCBs;
Or a PCB discharge limit included in a permit issued under
section 307(b) or 402 of the Clean Water Act.
Water containing PCBs regulated for disposal
- applicable
40 CFR § 761.79(b)(l)(ii)
40 CFR § 761.450(a)(3)
4
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Decontamination
standard for water
containing PCBs
For unrestricted use, meet standard of less than or equal to 0.5
ug/L (ie. Approximately i 0.5 ppb PCBs). .
Water containing PCBs regulated for disposal
- applicable
40 CFR § 761.79(b)(l)(iii)
Waste Characterization - Primary Wastes (contaminated media and debris) and Secondary Wastes (wastewaters, spent treatment media, etc.)
Characterization of solid
waste (all primary and
secondary wastes)
[e.g., excavated
sediments and soil]
Must determine if solid waste is a hazardous waste using the
following method:
Should first determine if waste is excluded from regulation
under 40 CFR261.4; and
Must then determine if waste is listed as a hazardous
waste under subpart D 40 CFR part 261.
Generation of solid waste as defined in 40
CFR261.2 - applicable
40 CFR § 262.11(a) and (b)
15A NCAC13A .0106, .107
Characterization of solid
waste (all primary and
secondary wastes)
[e.g., excavated
sediments and soil]
Must determine whether the waste is (characteristic waste)
identified in subpart C of 40 CFR part 261 by either:
(1) Testing the waste according to the methods set forth in
subpart C of 40 CFR part 261, or according to an equivalent
method approved by the Administrator under 40 CFR §260.21;
or
(2) Applying knowledge of the hazard characteristic of the
waste in light of the materials or the processes used.
40 CFR § 262.11(c)
15A NCAC 13A .0106
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 CFR § 262.11(d);
15A NCAC 13A .0106
Characterization of
hazardous waste (all
primary and secondary
wastes) [e.g., excavated
sediments apd soil]
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 CFR 264 and 268.
Generation of RCRA-hazardous waste for
storage, treatment or disposal - applicable
40 CFR § 264.13(a)(1)
15A NCAC 13A .0109
5
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Determinations for
management of
hazardous waste
[e.g., excavated
sediments and soil]
Must determine if the hazardous waste has to be treated before
land disposed. This is done by determining if the waste meets
the treatment standards in 40 CFR 268.40, 268.45, or 268.49 by
testing in accordance with prescribed methods or use of
generator knowledge of waste.
This determination can be made concurrently with the
hazardous waste determination required in 40 CFR § 262.11.
Generation of RCRA hazardous waste for
storage, treatment or disposal - applicable
40 CFR § 268.7(a)(1)
ISA NCAC 13A .0106
Must comply with the special requirements of 40 CFR § 268.9 in
addition to any applicable requirements in 40 CFR § 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 CFR § 268.7(a)(1)
15A NCAC 13A .0112
Must determine each EPA Hazardous Waste Number (waste
code) applicable to the waste in order to determine the
applicable treatment standards under 40 CFR 268 et seq..
Generation of RCRA characteristic hazardous
waste for storage, treatment or disposal -
applicable
40 CFR § 268.9(a)
15A NCAC 13A .0112
This determination may be made concurrently with the
hazardous waste determination required in Sec. 262.11 of this
chapter.
Must determine the underlying hazardous constituents [as
defined in 40 CFR 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
Section 268.42 Table 1) for storage,
treatment or disposal - applicable
40 CFR § 268.9(a)
ISA NCAC 13A .0112
Management of PCB
waste (e.g.,
contaminated PPE,
equipment, wastewater)
Any person storing or disposing of PCB waste must do so in
accordance with 40 CFR 761, Subpart D.
Generation of waste containing PCBs at
concentrations £ 50 ppm - applicable
40 CFR § 761.50(a)
Characterization of PCB
remediation waste
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 CFR 761.3 - applicable
40 CFR §761.61
6
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltatlon(s)
Waste Storage - Primary Wastes (contaminated media and debris) and Secondary Wastes (wastewaters, spent treatment media, etc.)
Storage of solid waste
All solid waste shall be stored in such a manner as to prevent
the creation of a nuisance, insanitary conditions, or a potential
public health hazard.
Generation of solid waste which is
determined not to be hazardous - relevant
and appropriate
15A NCAC 13B .0104(f)
Containers for the storage of solid waste shall be maintained in
such a manner as to prevent the creation of a nuisance or
insanitary conditions.
Containers that are broken or that otherwise fail to meet this
Rule shall be replaced with acceptable containers.
15A NCAC 13B .0104(e)
Temporary Storage of
hazardous waste in
containers
[e.g., excavated
sediments and soil]
A generator may accumulate hazardous waste at the facility
provided that:
waste is placed in containers that comply with 40 CFR
265.171-173; and
Accumulation of RCRA hazardous waste on
site as defined in 40 CFR §260.10 - applicable
40 CFR § 262.34(a);
15A NCAC 13A .0107
40 CFR §262.34(a)(l)(i);
the date upon which accumulation begins is clearly
marked and visible for inspection on each container;
container is marked with the words "hazardous
waste"; or
40 CFR § 262.34(a)(2) and (3)
15A NCAC 13A .0107
container may be marked with other words that
identify the contents.
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 CFR § 262.34(c)(1)
ISA NCAC 13A .0107
Use and management of
hazardous waste in
containers
[e.g., excavated
sediments and soil]
If container is not in good condition (e.g. severe rusting,
structural defects) or if it begins to leak, must transfer waste
into container in good condition.
Storage of RCRA hazardous waste in
containers - applicable
40 CFR § 265.171
15A NCAC 13A .0109
Use container made or lined with materials compatible with
waste to be stored so that the ability of the container is not
impaired.
40 CFR §265.172
15A NCAC 13A .0109
7
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Containers must be closed during storage, except when
necessary to add/remove waste.
Container must not opened, handled and stored in a manner
that may rupture the container or cause it to leak.
Storage of RCRA hazardous waste in
containers - applicable
40 CFR § 265.173(a) and (b)
15A NCAC 13A .0109
Storage of hazardous
waste in container area
[e.g., excavate
sediments and soil]
Area must have a containment system designed and operated
in accordance with 40 CFR §264.175(b).
Storage of RCRA-hazardous waste in
containers with free liquids - applicable
40 CFR §264.175(a)
15A NCAC 13A .0109
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 CFR § 264.175(c)(1) and (2)
15A NCAC 13A .0109
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 CFR
264.178 for containers.
Storage of RCRA hazardous waste in
containers - applicable
40 CFR §264.111
15A NCAC 13A .0109
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
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
with40 CFR 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 CFR § 264.178
15A NCAC 13A .0109
Temporary storage of
PCB waste in a
container(s)
Container(s) shall be marked as illustrated in 40 CFR 761.45(a).
Storage of PCBs and PCB Items at
concentrations > 50 ppm for disposal -
applicable
40 CFR § 761.40(a)(1)
Storage area must be properly marked as required by 40 CFR
761.40(a)(10).
40 CFR § 761.65(c)(3)
Any leaking PCB Items and their contents shall be transferred
immediately to a properly marked non-leaking container(s).
40 CFR § 761.65(c)(5)
Container(s) shall be in accordance with requirements set forth
in DOT HMR at 49 CFR 171-180.
40 CFR § 761.65(c)(6)
9
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Storage of liquid PCBs in
stationary containers
(e.g., leachate in storage
tank)
Storage containers can be larger than the containers specified in
paragraph (c)(6) of 40 CFR § 761.65 provided that:
The containers are designed, constructed, and
operated in compliance OSHA standards, 29 CFR
1910.106 Flammable and combustible liquids. Before
using these containers for storing PCBs, the design of
the containers must be reviewed to determine the
effect on the structural safety of the containers that
will result from placing liquids with the specific gravity
of PCBs into the containers.
Owner/operator shall prepare and implement a Spill
Prevention Control and Countermeasure (SPCC) Plan
as described in part 112 of this title.
NOTE: Substantive requirements of an SPCC Plan will be
contained in the CERCLA Remedial Action Work Plan.
Storage of liquid PCB in stationary containers
other than those meeting DOT HMR
performance standards at 49 CFR parts 171
through 180 - applicable
40 CFR § 761.65(c)(7)(i) and (ii)
Storage of PCB waste in
a RCRA-regulated
container storage area
Does not have to meet storage unit requirements in 40 CFR §
761.65(b)(1) provided unit:
is permitted by EPA under RCRA §3004, or
qualifies for interim status under RCRA §3005; or
Storage of PCBs and PCB Items designated for
disposal - applicable
40 CFR § 761.65(b)(2)(i)-(iv)
is permitted by an authorized state under RCRA §3006
and,
PCB spills cleaned up in accordance with Subpart G of
40 CFR 761.
NOTE: Storage unit meeting the requirements of the RCRA
ARARs for container storage unit identified above would
qualify as "interim status.
Clean closure of TSCA
storage facility
A TSCA/RCRA storage facility closed under RCRA is exempt from
the TSCA closure requirements of 40 CFR 761.65(e).
NOTE: This exemption would apply to storage of PCB waste
in a RCRA container storage unit that meets the RCRA
container unit requirements identified as ARARs.
Closure of TSCA/RCRA storage facility -
applicable
40 CFR § 761.65(e)(3)
10
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Actlon-Spedfic ARARs
Action
Requirements
Prerequisite
Citation(s)
Temporary storage of
bulk PCB remediation
waste (e.g., excavated
soils) in a TSCA 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 CFR § 761.65(c)(9)(i) and (ii)
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 CFR § 761.65(c)(9)(iii)(A)
Construction of TSCA
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.
Storage of PCB remediation waste or PCB
bulk product waste at cleanup site or site of
generation for up to 180 days - applicable
40 CFR § 761.65(c)(9)(iii)(A)(I)-(3)
Construction of TSCA
storage pile cover
The storage site must have a cover that:
meets the requirements of 40 CFR§
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 seasonal
meteorological conditions; and
Storage of PCB remediation waste or PCB
bulk product waste at cleanup site or site of
generation for up to 1'80 days - applicable
40 CFR § 761.65(c)(9)(iii)(B)
11
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Construction of TSCA
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.
Storage of PCB remediation waste or PCB
bulk product waste at cleanup site or site of
generation for up to 180 days - applicable
40 CFR § 761.65(c)(9)(iii)(C)(i) and
(2)
Modification of TSCA
waste pile requirements
Requirements of 40 CFR § 761.65(c)(9) may be modified under
the risk-based disposal option of 40 CFR 761.61(c).
NOTE: See ARAR entry below for requirements associated
with use of 40 CFR § 761.61(c).
40 CFR § 761.65(c)(9)(iv)
Temporary on-site
storage of remediation
waste in RCRA staging
pile (e.g., excavated
soils)
Must be located within the contiguous property under the
control of the owner/operator where the wastes are to be
managed in the staging pile originated.
For purposes of this section, storage includes mixing, sizing,
blending or other similar physical operations so long as
intended to prepare the wastes for subsequent management or
treatment.
Accumulation of solid non~flowlng
hazardous remediation waste (or
remediation waste otherwise subject to land
disposal restrictions) as defined in 40 CFR
260.10 - applicable
40 CFR § 264.554(a)(1)
Staging piles may be used to store hazardous remediation waste
(or remediation waste otherwise subject to land disposal
restrictions) based on approved standards and design criteria
designated for that staging pile.
NOTE: Design and standards of the staging pile should be
included in CERCLA Remedial Design document approved or
issued by EPA.
40 CFR § 264.554(b)
12
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Performance criteria for
RCRA staging pile
Staging pile must be designed to:
facilitate a reliable, effective and protective remedy;
must be designed to prevent or minimize releases of
hazardous wastes and constituents into the environment,
and minimize or adequately control cross-media transfer
as necessary to protect human health and the environment
(e.g. use of liners, covers, run-off/run-on controls).
Storage of remediation waste in a staging pile
-applicable
40 CFR § 264.554(d)(l)(i) and (ii)
Design criteria for RCRA
staging pile
In setting standards and design criteria must consider the
following factors:
Length of time pile will be in operation;
Volumes of waste you intend to store in the pile;
Physical and chemical characteristics of the wastes to
be stored in the unit;
Potential for releases from the unit;
Hydrogeological and other relevant environmental
conditions at the facility that may influence the
migration of any potential releases; and
Potential for human and environmental exposure to
potential releases from the unit.
Storage of remediation waste in a staging pile
- applicable
40 CFR § 264.554(d)(2)(i) -(vi)
Operation of a RCRA
staging pile
Must not place in the same staging pile unless you have
complied with 40 CFR § 264.17(b).
Storage of "incompatible" remediation waste
(as defined in 40 CFR 260.10) in staging pile -
applicable
40 CFR § 264.554(f)(1)
Must separate the incompatible waste or materials, or protect
them from one another by using a dike, berm, wall or other
device.
Staging pile of remediation waste stored
nearby to incompatible wastes or materials in
containers, other piles, open tanks or land
disposal units - applicable.
40 CFR § 264.554(f)(2)
Must not pile remediation waste on same base where
incompatible wastes or materials were previously piled unless
you have sufficiently decontaminated the base to comply with
40 CFR § 264.17(b).
40 CFR § 264.554(f)(3)
13
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Closure of RCRA staging
pile of remediation
waste
Must be closed within 180 days after the operating term by
removing or decontaminating all remediation waste,
contaminated containment system components, and structures
and equipment contaminated with waste and leachate.
Must decontaminate contaminated sub-soils in a manner that
EPA determines will protect human and the environment.
Storage of remediation waste in staging pile
in previously contaminated area - applicable
40 CFR § 264.554(j)(l) and (2)
Must be closed within 180 days after the operating term
according to 40 CFR § 264.258(a) and § 264.111 or §265.258(a)
and §265.111.
Storage of remediation waste in staging pile
in uncontaminated area - applicable
40 CFR § 264.554(k)
Operational limits of a
RCRA staging pile
Must not operate for more than 2 years, except when an
operating term extension under 40 CFR § 264.554(i) is granted.
NOTE: Must measure the 2-year limit (or other operating
term specified) from first time remediation waste placed in
staging pile
Storage of remediation waste in a staging pile
- applicable
40 CFR §264.554(d)(l)(iii)
Must not use staging pile longer than the length of time
designated by EPA in appropriate decision document.
40 CFR §264.554(h)
Treatment/Disposal of Wastes - Primary (contaminated media and debris) and Secondary Wastes (wastewaters, spent treatment media, etc.)
Disposal of solid waste
[e.g., off-site permitted
landfill]
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
[e.g., off-site permitted
landfill]
May be land disposed if it meets the requirements in the table
"Treatment Standards for Hazardous Waste" at 40 CFR § 268.40
before land disposal.
Land disposal, as defined in 40 CFR268.2, of
restricted RCRA waste - applicable
40 CFR § 268.40(a)
15A NCAC 13A .0112
All underlying hazardous constituents [as defined in 40 CFR §
268.2(i)] must meet the Universal Treatment Standards, found
in 40 CFR § 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 CFR §268.40(e)
15A NCAC 13A .0112
14
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Disposal of RCRA-
hazardous waste in a
land-based unit
[e.g., off-site permitted
landfill]
To determine whether a hazardous waste identified in this
section exceeds the applicable treatment standards of 40 CFR §
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.
If the waste contains constituents (including UHCs in the
characteristic wastes) in excess of the applicable UTS levels in
40 CFR § 268.48, the waste is prohibited from land disposal, and
all requirements of part 268 are applicable, except as otherwise
specified.
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 CFR § 268.34(f)
15A NCAC 13A .0112
Disposal of RCRA-
hazardous waste soil in a
land-based unit
[e.g., off-site permitted
landfill]
Must be treated according to the alternative treatment
standards of 40 CFR § 268.49(c) or according to the UTSs
[specified in 40 CFR § 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 CFR § 268.2, of
restricted hazardous soils - applicable
40 CFR § 268.49(b)
15A NCAC 13A .0112
Treatment of RCRA
hazardous waste soil
Prior to land disposal, all "constituents subject to treatment" as
defined in 40 CFR § 268.49(d) must be treated as follows:
Treatment of restricted hazardous waste soils
- applicable
40 CFR § 268.49(c)(1)
15
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citatlon(s)
Treatment of RCRA
hazardous waste soil
For non -metals (except carbon disulfide, cyclohexanone,
and methanol), treatment must achieve a 90 percent
reduction in total constituent concentrations, except as
provided in 40 CFR § 268.49(c)(1)(C)
For metals and carbon disulfide, cyclohexanone, and
methanol), treatment must achieve a 90 percent reduction
in total constituent concentrations as measured in leachate
from the treated media (tested according to TCLP) or 90
percent reduction in total constituent concentrations
(when a metal removal technology is used), except as
provided in 40 CFR § 268.49(c)(1)(C)
When treatment of any constituent subject to treatment
to a 90 percent reduction standard would result in a
concentration less than 10 times the Universal Treatment
Standard for that constituent, treatment to achieve
constituent concentrations less than 10 times the universal
treatment standard is not required. [Universal Treatment
Standards are identified in 40 CFR § 268.48 Table UTS]
NOTE: Treatment required for soils considered hazardous
waste is expected to be performed at an off-site RCRA
permitted facility prior to disposal,
Treatment of restricted hazardous waste soils
- applicable
40 CFR § 268.49(c)(l)(A)-(C)
Treatment of RCRA
hazardous waste soil
In addition to the treatment requirement required by paragraph
(c)(1) of this section, soils must be treated to eliminate these
characteristics.
Soils that exhibit the characteristic of
ignitability, corrosivity or reactivity intended
for land disposal - applicable
40 CFR § 268.49(c)(2)
Provides methods on how to demonstrate compliance with the
alternative treatment standards for contaminated soils that will
be land disposed.
On-site treatment of restricted hazardous
waste soils following alternative soil
treatment of 40 CFR § 268.49(c) - To Be
Considered
Guidance on Demonstrating
Compliance with the LDR
Alternative Soil Treatment
Standards [EPA 530 -R -02 -003,
July 2002]
16
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Disposal of RCRA
hazardous waste debris
in a land-based unit
[e.g., off-site permitted
landfill]
Must be treated prior to land disposal as provided in 40 CFR §
268.45(a)(1)(5) unless EPA determines under 40 CFR §
261.3(f)(2) that the debris no longer contaminated with
hazardous waste or the debris is treated to the waste -specific
treatment standard provided in 40 CFR 268.40 for the waste
contaminating the debris.
NOTE: Treatment required for hazardous waste debris is
expected to be performed at an off-site RCRA permitted
facility prior to disposal,
Land disposal, as defined in 40 CFR §268.2, of
restricted RCRA-hazardous debris-
applicable
40 CFR § 268.45(a)
Disposal of treated
hazardous debris in a
land-based unit
[e.g., off-site permitted
landfill]
Debris treated by one of the specified extraction or destruction
technologies on Table 1 of 40 CFR § 268.45 and which no longer
exhibits a characteristic is not'a hazardous waste and need not
be managed in RCRA Subtitle C facility
Hazardous debris contaminated with listed waste that is treated
by immobilization technology must be managed in a RCRA
Subtitle C facility.
NOTE: Treatment required for hazardous waste debris is
expected to be performed at an off-site RCRA permitted
facility prior to disposal,
Treated debris contaminated with RCRA
listed or characteristic waste - applicable
40 CFR § 268.45(c)
Disposal of hazardous
debris treatment
residues
Except as provided in 40 CFR § 268.45(d)(2) and (d)(4), must be
separated from debris by simple physical or mechanical means,
and such residues are subject to the waste -specific treatment
standards for the waste contaminating the debris
Residue from treatment of hazardous debris
- applicable
40 CFR § 268.45(d)(1)
Disposal of RCRA
characteristic
wastewaters in an
NPDES permitted WWTU
Are not prohibited, if the wastes are managed in a treatment
system which subsequently discharges to waters of the U.S.
pursuant to a permit issued under § 402 the CWA (i.e., NPDES
permitted) unless the wastes are subject to a specified method
of treatment other than DEACT in 40 CFR § 268.40, or are D003
reactive cyanide.
NOTE: For purposes of this exclusion, a CERCLA on-site
wastewater treatment unit that meets all of the identified
CWA ARARs for point source discharges from such a system,
is considered a wastewater treatment system that is NPDES
permitted.
Land disposal of hazardous wastewaters that
are hazardous only because they exhibit a
hazardous characteristic and are not
otherwise prohibited under 40 CFR Part 268 -
applicable
40 CFR § 268. l(c)(4)(i)
17
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltatlon(s)
Groundwater Monitoring Well Installation, Operation, and Abandonment
Groundwater monitoring
well(s)
Groundwater
Protection
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
15A NCAC 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.
15A NCAC02C .0108(c)
Construction of
groundwater monitoring
well(s)
Monitoring well and recovery well boreholes shall meet the
construction requirements set forth in the cited regulations
related to:
Borehole depth and connectivity
Packing material, well screen and seals
Grout placement and contents
Well casing and covers
Wellhead protection
Installation of wells (including temporary
wells, monitoring wells) and boreholes other
than for water supply - applicable
15A NCAC 02C .0108(d) thru
15A NCAC02C ,0108(p)
Standards of Construction
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(s)
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(p)
Maintenance of
groundwater monitoring
well(s)
Every well shall be maintained by the owner in a condition
whereby it will conserve and protect groundwater resources,
and whereby it will not be a source or channel of contamination
or pollution to the water supply or any aquifer.
Installation of wells (including temporary
wells and monitoring wells) other than for
water supply - applicable
15A NCAC 02C .0112(a)
18
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Abandonment of
groundwater monitoring
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
ISA 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)
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)
19
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Capping Waste In Place - (Landfill Final Closure and Post-closure Care)
Landfill closure
performance standard
(Areas F and G as well
as the former RCRA
surface impoundments
closed as landfills)
Must close the unit in a manner that:
minimizes the need for further maintenance; and
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 ground or surface waters
or to the atmosphere; and
complies with the relevant closure and post -closure
requirements of 40 CFR §264.310.
Closure of a RCRA hazardous waste
management unit - relevant and appropriate
40 CFR § 264.111(a)-(c)
15A NCAC 13A .0109
Landfill cover design and
construction
(Areas F and G)
Must cover the landfill or cell with a final cover designed and
constructed to:
provide long -term minimization of migration of
liquids through the closed landfill;
function with minimum maintenance;
promote drainage and minimize erosion or abrasion
of the cover;
accommodate settling and subsidence so that the
cover's integrity is maintained; and
have a permeability less than or equal to the
permeability of any bottom liner system or natural
sub-soils present.
Closure of a RCRA hazardous waste
management unit - relevant and appropriate
40 CFR § 264.310(a)(1)(5)
15A NCAC 13A .0109
20
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citatlon(s)
Landfill cover design and
construction
(Areas F and G)
Describes a design for landfill covers that will meet the
requirements of RCRA regulations. Multilayered system
consisting, from the top down, of:
a top layer of at least 60 cm of soil, either'vegetated
or armored at the surface;
a granular or geo-synthetic drainage layer with a
hydraulic transmissivity no less than 3 x 10"5 cm /sec;
and
a two-component low permeability layer comprised
of (1) a flexible membrane liner installed directly on
(2) a compacted soil component with an hydraulic
conductivity no greater than 1 x 10~7 cm/sec.
Optional layers may be added, e.g., a biotic barrier layer or a gas
vent layer, depending on the nature of the wastes being
covered.
Construction of a RCRA hazardous waste
landfill final cover - TBC
EPA Technical Guidance Document:
Final Covers on Hazardous Waste
Landfills and Surface
Impoundments, EPA OSWER 530-
SW -89 -047, (July 1989)
Run-on/run-off control
systems for landfill cover
(Areas F and G)
Run-on control system must be capable of preventing flow onto
the active portion of the landfill during peak discharge from a
25-year storm event.
Construction of a RCRA hazardous waste
landfill cover - relevant and appropriate
40 CFR § 264.301(g)
15A NCAC 13A .0109
Run-off management system must be able to collect and
control the water volume from a runoff resulting from a 24-
hour, 25-year storm event.
40 CFR § 264.301(h)
15A NCAC 13A .0109
Protection of closed
RCRA hazardous waste
landfill
(Areas F and G as well
as the former RCRA
surface impoundments
closed as landfills)
Post-closure use of property must never be allowed to disturb
the integrity of the final cover, liners, or any other components
of the containment system or the facility's monitoring system
unless necessary to reduce a threat to human health or the
environment.
Closure of a RCRA hazardous waste landfill -
relevant and appropriate
40 CFR § 264.117(c)
15A NCAC 13A .0109
21
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citatlon(s)
General post-closure
care for closed RCRA
hazardous waste landfill
(Areas F and G as well
as the former RCRA
surface impoundments
closed as landfills)
Owner or operator must:
- maintain the effectiveness and integrity of the final
cover including making repairs to the cap as necessary
to correct effects of settling, erosion, etc.;
maintain and monitor the groundwater monitoring
system and comply with all other applicable
requirements of RCRA Subpart F of this part;
prevent run-on and run-off from eroding or
otherwise damaging final cover; and
protect and maintain surveyed benchmarks used to
locate waste cells.
NOTE: Groundwater detection monitoring in accordance
with 40 CFR 264.98 will be continued for the SWDS only.
Monitoring requirements will be specified in a CERCLA
Remedial Design or Remedial Action Work Plan.
Closure of a RCRA hazardous waste landfill -
relevant and appropriate
40 CFR § 264.310(b)(1), (4), (5) and
(5)
15A NCAC13A .0109
Solid Waste Landfill
cover design and
construction
(capping upland soil
contamination)
Shall install a cap system that is designed to minimize
infiltration and erosion. The cap system shall be designed and
constructed to:
(A) Have a permeability less than or equal to the permeability
of any base liner system or the in-situ subsoils underlaying the
landfill, or the permeability specified for the final cover in the
effective permit, or a permeability no greater than 1 x 10-5
cm/sec, whichever is less;
(B) Minimize infiltration through the closed MSWLF by the use
of a low-permeability barrier that contains a minimum 18
inches of earthen material; and
(C) Minimize erosion of the cap system and protect the low-
permeability barrier from root penetration by use of an
erosion layer that contains a minimum of six inches of earthen
material that is capable of sustaining native plant growth.
Closure of a solid waste landfill (MSWLF) -
relevant and appropriate
15A NCAC 13B .1627(c)(1)
22
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Solid Waste Landfill
cover design and
construction
(capping upland soil
contamination)
The Division may approve an alternative cap system if the
owner or operator can adequately demonstrate the following:
(A) The alternative cap system will achieve an equivalent or
greater reduction in infiltration as the low-permeability
barrier specified in Subparagraph (1) of this Paragraph; and
(B) The erosion layer will provide equivalent or improved
protection as the erosion layer specified in Subparagraph (3)
of this Paragraph.
NOTE: In the event an alternative cover is sought, approval
will be documented in a CERCLA decision document and
NCDEQ concurrence obtained.
Closure of a solid waste landfill (MSWLF) -
relevant and appropriate
ISA NCAC 13B .1627(c)(2)
General post-closure
care for closed Solid
Waste Landfill
Maintaining the integrity and effectiveness of any cap system,
including making repairs to the cover as necessary to correct
the effects of settlement, subsidence, erosion, or other events,
and preventing run-on and run-off from eroding or otherwise
damaging the cap system.
Closure of a solid waste landfill (MSWLF) -
relevant and appropriate
15A NCAC 13B .1627(d)(1)(A)
Treatment/Disposal of PCB waste (Including PCB remediation waste and leachate)
Disposal of
decontamination waste
and residues
Such waste shall be disposed of at their existing PCB
concentration unless otherwise specified in 40 CFR §
761.79(g)(1)-(6).
Decontamination waste and residues -
applicable
40 CFR § 761.79(g)
Are regulated for disposal as PCB remediation waste.
Distillation bottoms or residues and filter
media - applicable
40 CFR § 761.79(g)(1)
Are regulated for disposal at their original concentration.
PCBs physically separated from regulated
waste during decontamination, other than
distillation bottoms and filter media -
applicable
40 CFR § 761.79(g)(2)
Shall be disposed of in accordance with provisions for wastes
from cleanup of PCB remediation waste at 40 CFR §
761.61(a)(5)(v).
Non-liquid cleaning materials and PPE at any
concentration PCBs, including non-porous
surfaces and other non-liquid materials (e.g.,
rags, gloves, booties) resulting from
decontamination - applicable
40 CFR § 761.79(g)(6)
23
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citatlon(s)
Disposal of PCB
contaminated
precipitation,
condensation, and
leachate
May be disposed in a chemical waste landfill which complies
with 40 CFR § 761.75 if:
disposal does not violate 40 CFR § 268.32(a) or §
268.42(a)(1);
liquids do not exceed 500 ppm PCB and are not an ignitable
waste as described in 40 CFR § 761.75(b)(8)(iii).
PCB liquids at concentrations 2: 50 ppm and <,
500 ppm from incidental sources such as
precipitation, condensation, leachate or load
separation and associated with PCB Articles
or non-liquid PCB wastes - applicable
40 CFR § 761.60(a)(3)
40 CFR § 761.60(a)(3)(i) and (ii)
Disposal of PCB
contaminated porous
surfaces (self-
implementing option)
Shall be disposed on-site or off-site as bulk PCB remediation
waste according to 40 CFR 761.61(a)(5)(i) or decontaminated
for use according to 40 CFR 761.79(b)(4).
PCB remediation waste porous surfaces (as
defined in 40 CFR 761.3) - relevant and
appropriate
40 CFR § 761.61(a)(5)(iii)
Disposal liquid PCB
remediation waste (self-
implementing option)
Shall either:
decontaminate the waste to the levels specified in 40
CFR 761.79(b)(1) or (2); or
dispose of the waste in accordance with 40 CFR
761.61(b) or a risk-based approval under 40 CFR
761.61(c).
Liquid PCB remediation waste (as defined in
40 CFR 761.3) - relevant and appropriate
40 CFR § 761.61(a)(5)(iv)
40 CFR § 761.61(a)(5)(iv)(A) and (B)
Disposal of PCB
contaminated non-
porous surfaces on-site
(self- implementing
option)
Shall be cleaned on-site or off-site to levels in 40 CFR
761.61(a)(4)(H) using:
decontamination procedures under 40 CFR 761.79;
technologies approved under 40 CFR 761.60(e); or
risk-based procedures/technologies under 40 CFR
761.61(c).
PCB remediation waste non-porous surfaces
(as defined in 40 CFR 761.3) - relevant and
appropriate
40 CFR § 761.61(a)(5)(ii)(A)(l)-(3)
Disposal of bulk PCB
remediation waste off-
site (self-implementing
option)
May be sent off-site for decontamination or disposal provided
the waste is either dewatered on-site or transported off-site in
containers meeting the requirements of DOT HMR at 49 CFR
parts 171-180.
Generation of bulk PCB remediation waste (as
defined in 40 CFR 761.3) for disposal -
relevant and appropriate
40 CFR § 761.61(a)(5)(i)(B)
Shall be disposed of in accordance with the provisions for
Cleanup wastes at 40 CFR 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 CFR § 761.61(a)(5)(i)(B)(2)(//j
24
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Disposal of bulk PCB
remediation waste off-
site (self-implementing
option)
Shall be disposed of:
in a hazardous waste landfill permitted by EPA under
§3004 of RCRA;
in a hazardous waste landfill permitted by a State
authorized under §3006 of RCRA; or
in a PCB disposal facility approved under 40 CFR
761.60.
Bulk PCB remediation waste which has been
de-watered and with a PCB concentration 2:
50 ppm - relevant and appropriate
40 CFR § 761.61(a)(5)(i)(B)(2)(/i/;
Performance-based
disposal of PCB
remediation waste
Shall dispose by one of the following methods:
in a high-temperature incinerator approved under 40
CFR 761.70(b);
by an alternate disposal method approved under 40
CFR 761.60(e);
in a chemical waste landfill approved under 40 CFR
761.75;
in a facility with a coordinated approval issued under
40 CFR 761.77; or
through decontamination in accordance with 40 CFR
761.79.
NOTE: On-site TSCA chemical waste landfill that complies
with the ARARs identified in this table in the signed ROD
would be considered an approved landfill.
Disposal of non-liquid PCB remediation waste
(as defined in 40 CFR 761.3) - relevant and
appropriate
40 CFR § 761.61(b)(2)
40 CFR § 761.61(b)(2)(i)
40 CFR § 761.61(b)(2)(ii)
Shall be disposed according to 40 CFR 761.60(a) or (e), or
decontaminate in accordance with 40 CFR 761.79.
Disposal of liquid PCB remediation waste -
relevant and appropriate
40 CFR § 761.61(b)(1)
25
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Table A-3. Action-Specific ARARs and TBCs
for LCP Hoitrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Risk-based disposal of
PCB remediation waste
May sample, cleanup or dispose of PCB remediation waste in a
manner other than prescribed in 40 CFR 761.61(a) or (b) or
store remediation waste in a manner other than prescribed in
40 CFR § 761.65 if application approved in writing by EPA
Regional Administrator and EPA finds that the method will not
pose an unreasonable risk of injury to [sic] human health or the
environment.
Each application must include information described in 40 CFR §
761.61(a)(3).
NOTE: Appropriate information required in an application
can be provided in a CERCLA document (e.g. FS, PP, or ROD)
that is approved or issued by EPA.
Disposal of PCB remediation waste -
relevant and appropriate
40 CFR § 761.61(c)
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 CFR
258 or non-municipal, non-hazardous waste subject
to 40 CFR 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 CFR 761.79(b) or
(c).
NOTE: On-site TSCA chemical waste landfill that complies
with the ARARs identified in this table in the signed ROD
would be considered an approved PCB disposal facility.
Generation of non-liquid PCBs at any
concentration during and from the cleanup of
PCB remediation waste - relevant and
appropriate
40 CFR § 761.61(a)(5)(v)(A)(l)-(4)
Disposal of PCB cleaning
solvents, abrasives, and
equipment (self-
implementing option)
May be reused after decontamination in accordance with 40
CFR § 761.79; or
For liquids, disposed in accordance with 40 CFR 761.60(a).
Generation of PCB wastes from the cleanup
of PCB remediation waste - relevant and
appropriate
40 CFR § 761.61(a)(5)(v)(B)
40 CFR § 761.60(b)(l)(i)(B)
26
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
TSCA Chemical Waste Landfill Design and Operation
Synthetic liner for a TSCA
chemical waste landfill
Synthetic membrane liners shall be used when, in the judgment
of the Regional Administrator, the hydrologic or geologic
conditions at the landfill require such a liner in order to provide
at least a permeability equivalent to the soils in paragraph (b)(1)
of this section.
Whenever a synthetic liner is used at a landfill site, special
precautions shall be taken to insure that its integrity is
maintained and that it is chemically compatible with PCBs.
Adequate soil underlining and cover shall be provided to
prevent excessive stress on the liner and to prevent rupture of
the liner. The liner must have a minimum thickness of 30 mils.
Construction of a TSCA chemical waste
landfill - applicable
40 CFR § 761.75(b)(2)
Surface water and
Groundwater monitoring
for TSCA chemical
landfill
For all sites receiving PCBs, the ground and surface water from
the disposal site area shall be sampled prior to commencing
operations under an approval provided in paragraph (c) of this
section for use as baseline data.
Construction of a TSCA chemical waste
landfill - applicable
40 CFR §761.75 (b)(6)(i)(A)
Surface water
Any surface watercourse designated by the Regional
Administrator using the authority provided in paragraph(c)(3)(ii)
of this section shall be sampled at least monthly when the
landfill is being used for disposal operations.
Operation of TSCA chemical waste landfill
monitoring program - applicable
40 CFR § 761.75(b)(6)(i)(B)
Any surface watercourse designated by the Regional
Administrator using the authority provided in paragraph
(c)(3)(ii) of this section shall be sampled for a time period
specified by the Regional Administrator on a frequency of no
less than once every six months after final closure of the
disposal area.
40 CFR § 761.75(b)(6)(i)(C)
Groundwater monitoring
for TSCA chemical
landfill
If underlying earth materials are homogenous, impermeable,
and uniformly sloping in one direction, only three sampling
points shall be necessary. These three points shall be equally
spaced on a line through the center of the disposal area and
extending from the area of highest water table elevation to the
area of the lowest water table elevation.
Operation of TSCA chemical waste landfill
groundwater monitoring program -
applicable
40 CFR § 761.75(b)(6)(ii)(A)
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Groundwater monitoring
wells
All monitor wells shall be cased and the annular space between
the monitor zone (zone of saturation) and the surface shall be
completely backfilled with Portland cement or an equivalent
material and plugged with Portland cement to effectively
prevent percolation of surface water into the well bore. The
well opening at the surface shall have a removable cap to
provide access and to prevent entrance of rainfall or storm
water runoff. The groundwater monitoring well shall be
pumped before obtaining a sample for analysis to remove the
volume of liquid initially contained in the well. The discharge
shall be treated to meet applicable state or federal standards or
recycled to the chemical waste landfill.
40 CFR § 761.75(b)(6)(ii)(B)
Water analysis
requirements
As a minimum, all samples [groundwater and surface water]
shall be analyzed for the following parameters: PCBs, pH,
specific conductance, chlorinated organics and all data and
records of the sampling and analysis shall be maintained as
required in § 761.180(d)(1). Sampling methods and analytical
procedures for these parameters shall comply with those
specified in 40 CFR Part 136, as amended in 41 Federal Register
52779 on December 1,1976.
Operation of TSCA chemical waste landfill
groundwater monitoring program -
applicable
40 CFR §761.75 (b)(6)(iii)
Leachate collection
system for TSCA landfill
A leachate collection monitoring system shall be installed above
the chemical waste landfill. Leachate collection systems shall be
monitored monthly for quantity and physic<)chemical
characteristics of leachate produced. The leachate should be
either treated to acceptable limits for discharge in accordance
with a State or Federal permit or disposed of by another State
or Federally approved method. Water analysis shall be
conducted as provided in 40 CFR § 761.75(b)(6)(iii). Acceptable
leachate monitoring/collection systems shall be any of the
following designs, unless a waiver is obtained pursuant to
paragraph (c)(4) of this section.
NOTE: Leachate monitoring, including sampling and analysis
will be conducted in accordance with parameters
established in an EPA approved Long-term Monitoring
Program document that incorporates the ARARs listed in
this table.
Construction of a TSCA chemical waste
landfill - applicable
40 CFR § 761.75(b)(7)
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citatlon(s)
Simple leachate
collection
This system consists of a gravity flow drainfield installed above
the waste disposal unit liner. This design is recommended for
use when semi-solid or leachable solid wastes are placed in a
lined pit excavated into a relatively thick, unsaturated,
homogenous layer of low permeability soil.
Construction of a TSCA chemical waste
landfill - applicable
40 CFR § 761.75(b)(7)(i)
Compound leachate
collection
A compound leachate collection system consists of a gravity
flow drainfield installed above the waste disposal unit liner and
above a secondary installed liner.
40 CFR § 761.75(b)(7)(ii)
TSCA chemical waste
landfill operations
Shall be placed in manner that will prevent damage to
containers or articles. Other wastes that are not chemically
compatible with PCBs shall be segregated from the PCBs
throughout the handling and disposal process.
Disposal of PCBs or PCB Items in chemical
waste landfill - applicable
40 CFR § 761.75(b)(8)(i)
An operation plan shall be developed and submitted to the
Regional Administrator for approval as required in paragraph (c)
of this section. This plan shall include detailed explanations of
the procedures to be used for recordkeeping, surface water
handling procedures, excavation and backfilling, waste
segregation burial coordinates, vehicle and equipment
movement, use of roadways, leachate collection systems,
sampling and monitoring procedures, monitoring wells,
environmental emergency contingency plans, and security
measures to protect against vandalism and unauthorized waste
placements.
NOTE: Contents of the operation plan will be provided in a
CERCLA Remedial Design and/or Remedial Action Work
Plan.
Disposal of PCBs or PCB Items in chemical
waste landfill - applicable
40 CFR § 761.75(b)(8)(H)
\
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
TSCA chemical waste
landfill operations
con't
Bulk liquids not exceeding 500ppm PCBs may be disposed of
provided such waste is pretreated and/or stabilized (e.g.,
chemically fixed, evaporated, mixed with dry inert absorbent) to
reduce its liquid content or increase its solid content so that a
non-flowing consistency is achieved to eliminate the presence
of free liquids prior to final disposal.
Container of liquid PCBs with a concentration between 50 and
500 ppm PCB may be disposed of if each container is
surrounded by an amount of inert sorbent material capable of
absorbing all of the liquid contents of the container.
Disposal of dispose of liquid wastes
containing between 50 ppm and 500 ppm
PCB in chemical waste landfill - applicable
40 CFR § 761.75(b)(8)(ii)
Support facilities
A 6 ft. woven mesh fence, wall, or similar device shall be placed
around the site to prevent unauthorized persons and animals
from entering.
Construction of a TSCA chemical waste
landfill - applicable
40 CFR § 761.75(b)(9)(i)
Roads shall be maintained to and within the site that are
adequate to support the operation and maintenance of the site
without causing safety or nuisance problems or hazardous
conditions.
40 CFR § 761.75(b)(9)(ii)
Wind dispersal control
system
The site shall be operated and maintained in a manner to
prevent safety problems or hazardous conditions resulting from
spilled liquids and windblown materials.
40 CFR § 761.75(b)(9)(iii)
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Cltation(s)
Decontamination/Cleanup of PCB Waste
Decontamination of PCB
contaminated water
For discharge to a treatment works as defined in 40 CFR § 503.9
(aa), or discharge to navigable waters, meet standard of < 3 ppb
PCBs; or
For unrestricted use, meet standard of S 0.5 ppb PCBs.
Water containing PCBs regulated for disposal
- applicable
40 CFR § 761.79(b)(l)(ii)
40 CFR § 761.79(b)(l)(iii)
Decontamination of
movable equipment
contaminated by PCBs
(self-implementing
option)
May decontaminate by:
swabbing surfaces that have contacted PCBs with a
solvent;
a double wash/rinse as defined in 40 CFR 761.360-
378; or
another applicable decontamination procedure under
40 CFR § 761.79.
Movable equipment contaminated by PCBs
and used in storage areas, tools and sampling
equipment - relevant and appropriate
40 CFR § 761.79(c)(2)
Transportation of Wastes - Primary and Secondary
Transportation of PCB
wastes off-site
Must comply with the manifesting provisions at 40 CFR §
761.207 through § 761.218.
Relinquishment of control over PCB wastes by
transporting, or offering for transport -
applicable
40 CFR § 761.207(a)
Transportation of
hazardous materials
Shall be subject to and must comply with all applicable
provisions of the HMTA and DOT HMR at 49 CFR §§ 171-180.
Any person who,, transports "in commerce,"
or causes to be transported or shipped, a
hazardous material, including each person
performing pre-transportation functions
under contract with any department, agency,
or instrumentality of the executive,
legislative, or judicial branch of the Federal
government - applicable
49 CFR § 171.1(b) and (c)
Transportation of
hazardous waste off site
Must comply with the generator requirements of 40 CFR Sect.
262.20-23 for 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, 262.41(a) for record keeping
requirements and Sect. 262.12 to obtain EPA ID number.
Preparation and initiation of shipment of
RCRA hazardous waste off-site - applicable
40 CFR § 262.10(h)
15A NCAC 13A .0108
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Transportation of
hazardous waste on-site
The generator manifesting requirements of 40 CFR Sections
262.20-262.32(b) do not apply. Generator or transporter must
comply with the requirements set forth in 40 CFR § 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 CFR § 262.20(f)
15A NCAC 13A .0108
Management of samples
(i.e., contaminated soils
and wastewaters)
Are not subject to any requirements of 40 CFR 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; and
The sample collector ships samples to a laboratory in
compliance with U.S.DOT, U.S. Postal Service, or any
other applicable shipping requirements, including
packing the sample so that it does not leak, spill or
vaporize from its packaging.
Generation of samples of hazardous waste
for purpose of conducting testing to
determine its characteristics or composition -
applicable
40 CFR § 261.4(d)(l)(i) and (ii)
15A NCAC 13A .0108
40 CFR § 261.4(d)(2)
15A NCAC 13A .0108
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Institutional Controls
Post-closure notices
(former RCRA surface
impoundments closed
as landfill)
Must record, in accordance with State law, a notation on the
deed to the facility 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 that:
Land has been used to manage hazardous wastes;
Its use is restricted under 40 CFR Part 264 Subpart G
regulations; and
The survey plat and record of the type, location, and quantity of
hazardous wastes disposed within each cell or other hazardous
waste disposal unit of the facility required by Sections 264.116
and 264.119(a) have been filed with the local zoning authority
and with the EPA Regional Administrator.
Closure of a RCRA hazardous waste landfill -
applicable
40 CFR § 264.119(b)(l)(i)-(iii)
15A NCAC 13A .0109
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)
The 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)
Notice of Contaminated
Site con't
Notice (survey plat) shall be filed in the register of deeds office
in the county which the site is located in the grantor index
under the name of the owner.
N.C.G.S. 143B-279.10(b) and (c)
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Table A-3. Action-Specific ARARs and TBCs
for LCP Holtrachem Superfund Site Riegelwood, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
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 sold, leased,
conveyed or transferred TBC
N.C.G.S. 143B-279.10(e)
ARAR = applicable or relevant and appropriate requirement
CFR = Code of Federal Regulations
CWA = Clean Water Act of 1972
DOT = U.S. Department of Transportation
EPA = U.S. Environmental Protection Agency
HMR = Hazardous Materials Regulations
HMTA = Hazardous Materials Transportation Act
MSWF = Municipal solid waste landfill
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
PPE = personal protective equipment
RCRA = Resource Conservation and Recovery Act of 1976
SWDS = Solid waste Disposal Site
TBC = to be considered
TSCA = Toxic Substances Control Act of 1976
U.S. = United States
UTS = Universal Treatment Standard
WWTU = waste water treatment unit
> = greater than
< = less than
2 = greater than or equal to
£ = less than or equal to
34
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APPENDIX B
TRANSCRIPT FROM PROPOSED PLAN PUBLIC MEETING
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Deposition of
Date: August 23, 2016
Volume: I
Case: IMO: Holtrachem Site, Riegelwood, NC
Aurelia Ruffin _ Associates, Inc.
Phone:(910)343-1035
Email:pbruffiniii@att.net
Internet: www.peterruffin.com
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U.S. ENVIRONMENTAL PROTECTION AGENCY
HOLTRACHEM SITE
RIEGELWOOD, NORTH CAROLINA
PUBLIC MEETING TO DISCUSS THE PROPOSED
HOLTRACHEM SITE CLEANUP PLAN
RIEGELWOOD, NC
REPORTED BY:
TAMARA A. VIOLETTE, Notary Public and Court Reporter
AURELIA RUFFIN & ASSOCIATES, INC.
215 South Water Street, #104
Post Office Box 2025
Wilmington, North Carolina 28402
pbruffiniii0att.net
TELEPHONE: 910-343-1035
DATE REPORTED: August 23, 2016
LOCATION: Riegelwood, N.C.
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APPEARANCES
For the EPA: SAMANTHA URQUHART-FOSTER
RONALD TOLLIVER
Environmental Protection Agency
Sam Nunn Federal Center
61 Forsyth Street, SW
11th Floor
Atlanta, GA 30303
404-562-9591
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(The Hearing commenced at 7:15 p.m.)
MR. TOLLIVER: Good evening, everyone. Welcome to
our proposed plan meeting, and I do want to thank you all
for coming out, and I do want to say I really, really enjoy
being here in Wilmington. Very nice, very pleasant place.
But we're going to get ready to get started with a proposed
plan presentation with our project manager here, Samantha
Foster. So with our the purpose of this meeting is to
really highlight our plan for clean up in the Holtrachem
site.
So we want to make sure you guys understand where
we're coming from so we can get some input also from
community members as well. This is really an important
time, kind of get the ball rolling and get things started
with the clean up and also reuse of the site.
Samantha, the first slide here is from The Superfund
Process, and I'm sure most of you are familiar with it, but
we start out with kind of like the site investigation phase
is in the beginning, down there at the bottom; and then we
move on once you investigate a site you move on to
listing it on the National Priorities List. That way it
can get funded.
Then from there we move onto our remedial
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investigation. So we investigate the feasibility study,
seeing what all the resources that it's going to take to
actually clean it up to come up with the best plan to
plan of.action, basically. That's where we're at now,
we're at a plan of action, or proposed plan. We want to
propose it to the community, and get some input and see how
it will impact the community and get some input or comments
so that we can take into consideration before we move onto
our record of decision; kind of like a finalizing document
that says, okay, this is what EPA is going to be
responsible in doing to clean up this site here,
Holtrachem.
So the rest of it will go into -- and Samantha is
going to really describe this, the options that she went
through, and also the one that we're going to recommend for
this site. So Samantha, do you want to just kind of
explain it?
MS. URQUHART-FOSTER: Hi, I'm Samantha
Urquhart-Foster for those of you that I haven't met yet.
I'm a remedial project manager for the EPA, particularly
for this site. We have got a huge team of people that are
working with us on this project, but the people that we
have here tonight are myself; Ron Tolliver, Community
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Involvement Coordinator; I have Dave Mattison with North
Carolina; Prashant Gupta with Honeywell; Cynthia Draper and
Walker Jones with Amec; and we have got a whole team of
people back in the office that weren't able to come here
tonite.
The site itself is located in Riegelwood. From where
we are now it's you shoot down through IP. You have to
drive through IP to get there. It's surrounded by
International Paper with the Cape Fear River on the other
border. The facility was developed in 1963, I believe, and
was constructed; they prepared manufactured, it was
chlor-alkali facility. They manufactured hydrochloric
acid, chlorine dioxide and other chemicals to give to IP as
well as just to sell to other facilities. It operated
until 2000.
EPA has been involved with the site since 1999.
Before that, North Carolina RCRO was involved with the
project. In 1999 Hurricane Floyd came through and the EPA
provided emergency response activities and then the
facility¦stopped operation in 2000. EPA came in and
oversaw the removal action that Honeywell's conducting in
2003 and 2004 then, again, in 2008 there was another
removal that was done.
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Hurricane Floyd came in and there were about 24 inches
of rain that fell in that process and it caused the a
breach of the stormwater retention basin. So the water
that was contained on-site breached out' of the basin and
spilled into the Cape Fear River. It was about 2.2
million gallons of water that was released and a had a
small amount of mercury in it.
Then in 2003 and 2004 EPA oversaw the removal action
that Honeywell and their contractors did. They tore down
the former mercury cell building, they containerized all
the waste that was on-site and transported it off-site.
There was, we were told, about 4 million pounds of waste
that was removed from the site. There was about 34,000
pounds of mercury, a lot of scrap metal; brass, mercury,
copper, titanium, as well as other hazardous materials that
were transported off-site. So the majority of waste that
was at the site has already been removed. What we're
dealing with now is residual.
In 2008 we learned that back historically the waste
water that was at Holtrachem was transferred to
International Paper for treatment before it was disposed or
released. International Paper did some sampling in the
lagoon where they wanted to build another landfill cell in
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and it was found it was contaminated with PCBs. So after
they discovered that and let us know, there was a removal
action that was done and about 24,000 cubic yards of
mercury I'm sorry, PCB contaminated soil, sludge was
transferred over to the Holtrachem site for storage until
we could get to their clean up plan.
The site has been divided in, like, three areas.
There's an upland process area, upland nonprocess area and
wooded bottomland area. The green is the bottomland area
which borders the Cape Fear River. Yellow is a processing
area and orange is the nonprocessing area.
So the scope and role to the remedial action is going
to address any remaining contamination at the site.
Groundwater is contaminated but it's not of usable -- it's
not usable. So, I mean, our primarily our primary
concern is to address the contaminated soil, sediment,
surface water and we're going to do groundwater monitoring.
The main risk at the site; land use is currently
industrial. We see it being industrial in the future. To
get there you have to drive through International .Paper.
So we don't see any residential use in the future. It will
either be industrial or wildlife habitat. Groundwater use
hadn't -- I mean, groundwater hasn't been used at the site
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ever. Groundwater has been drinking water's been
provided by International Paper in the past and we see that
proceeding into the future.
The exposed populations are industrial workers,
trespassers and wildlife. The human health risk associated
with the site include industrial work, construction workers
or trespassers onto the project. The site is fenced on
three sides. You can only get there is to drive through
International Paper and then the site's fenced. It's got
people on-site managing the property. The only nonfenced
-side is on the Cape Fear River and there's a huge drop off
between the site and the river. So it's like somebody
decided to drive their boat up and come up is really the
only way they could get access to it.
For the ecological risks, we did an ecological risk
assessment. We found the primary receptors that were at
harm were the green, Blue Heron, the Carolina Red and
amphibian and micro invertebrates, based on toxicity
testing.
This is the conceptual site model. The areas in
purple are the areas that are primarily contaminated with
mercury and PCBs. And as you can see, some of the
buildings that are shown in purple. So this building here
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by the arrow in purple no longer exists. It was the former
mercury cell building. That's been dismantled. The rest
of.the contamination are the areas in purple.
So our remedial action objectives are primarily
cleaning up the site so it's safe for human -- human use
and wildlife. The main contaminants are mercury and
Araclor 1268 which is a PCB.
We developed remediation goals based on human health
and ecological risk assessments. So we came out with these
clean up levels. We had concentrations of PCBs or Araclor
1268, for example, in the upland area up to 2700 micrograms
per kilogram. We're proposing 11 milligrams per kilogram,
so clean up level. We have other mercury clean up level
we're proposing is 536 and that's all based on risk
assessments, assuming that it's going to be industrial use
at the site.
The wooded bottomland area is slightly different.
That area there's a lot of wildlife down there; and our
goal is to protect the wildlife in that area. So we have
lower clean up goals for that. In the wooded bottomland
area, for example, we have 3 milligrams per kilogram to
clean up for mercury versus 500 something in the upland
area.
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During the feasibility study of this process the
contractors consulted and they looked at different areas
and different alternatives and came up with 6 different
alternatives for the majority of the site, and I'm just
going to hit on the key ones. Our preferred remedy is
Alternative 3 and the rest of the alternatives are included
in the proposed plan. I don't know if you have a copy of
that. If you don't we can give one to you.
So the 6 alternatives for the soil and sediment for
the majority of the site include no action, which we have
to do as a matter of the National Contingency Plan requires
us to look at no action. That's obviously not going to be
for this site because of the contamination of the site and
that we're not comfortable with.
Alternative 2 is capping with limited excavation with
off-site disposal or on-site treatment. Institutional
controls and engineering controls.
Alternative 3, which is our preferred remedy, is a
combination of capping, excavation, on-site disposal and
institutional controls; and A4 is similar but it's, you
know, different areas of capping.
A5, excavation and on-site disposal. A6 is excavation
with off-site disposal. I'll go into a little more detail
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in each of these.
There are two areas at the site which are different
than everyone else, F and G; and those have separate
alternatives. There's no action for A1 or SI, which we
don't agree with. Our preferred alternative is S3, which
is capping within in-situ stabilization, solidification and
capping and ICs, Institution Controls.
So the common elements, all 6 of the alternatives
include capping and erosion control along the berm in the
upland nonprocess area. There's one area that needs to be
capped. They all include clean out and closing stormwater
conveyance system, dewatering and off-site disposal of the
materials from the stormwater system; decommissioning the
stormwater treatment system; operation and maintenance is
substantially controls, engineering controls and five year
reviews.
Again, we looked at 6 alternatives. I'm just going to
list or show us the one for what we propose. You can
but I have got other slides if you want to see what the
other alternatives are. What we're proposing doing is
Alternative A3 and that includes excavation and capping as
well as containing the waste, any excavated waste on-site
into a landfill. The plan is to create a chemical waste
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landfill on-site that's going to be equivalent with the
commercial chemical waste landfill. It includes excavating
about 15,000 cubic yards of contaminated soil, as well as
disposing of 39,000 cubic yards of contaminated soil,
sludges into the landfill. It will take about ten two
years to complete and about 13.3 million dollars.
For the more contaminated areas where the former
mercury cell building was here at area G, we don't have a
lot of data for that cell. Right now there is a top
material on top of it and we're planning on capping it and
solidifying the waste in place. As well, in area F where
it was the former mercury cell building.
I might have that backwards. I'm sorry, F is where
the retort pad area was and G is the former mercury cell
building.
So to solidify that waste in place and cap it is gonna
be about 2.9 million dollars and take about a year or two.
Again, we looked at 6 different alternatives for the upland
area and four different areas for F and G and we in the
National Contingency Plan we're supposed to look at 9
different criteria; and there's a trade off of which
alternatives are better than others. And so Alternative 1
is no action. That's not good for any of us.
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So, again, our preferred alternative is to excavate
the contaminated area, the wooded bottomland areas; bring
it.up; construct an on-site chemical waste landfill; put
the contamination from the wooded bottomland areas, as well
as the soil that was excavated from International Paper,
and put it into their chemical waste landfill on-site.
This is.kind of a conceptual drawing of the actual
location, and the area may change during the remedial
design; but this is kind of a conceptual idea of what we
are planning on doing.
Community participation; we have established an
information repository at the public library just across
the street, and we're accepting public comments on this
until September 14th. So you probably just got a flyer in
the mail, which is like a two page summary. If you want to
see much more about the project, what's involved as far as
the feasibility study and the full proposed plan, it's
available in the library if you want to look at it. We're
accepting comments here tonite or you can Email them to me
or send them through regular mail.
David Mattison is here with North Carolina and part of
the nine criteria in the National Contingency Plan is State
acceptance.
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MR. MATTISON: The State has concurred with the
proposed clean up plan.
MS. URQUHART-FOSTER: There 'are other community
involvement activities that we have in the Superfund
process. I'll let Ron speak to the groups, they can form
and request a technical assistance grant to hire technical
consultants to explain things better to the community if
community members have difficulty understanding the
technical content. Again, we have got the public record or
the majority of the documents that are gonna be supporting
this decision are in the library.
MR. TOLLIVER: Any questions? Y'all have any
questions, would you please say the question and just state
your name for the reporter and if you represent an
organization just let us know.
MS. SORG: I'm Lisa Sorg, S-o-r-g. I'm from NC
Policy Watch in Raleigh. I'm a reporter, and I had a
question about surface water in the Cape Fear and fish.
You know, is there a fish advisory? I'm wondering if
there's sediment issues in the Cape Fear outside the scope
of this, or how would that be addressed, if at all?
MS. URQUHART-FOSTER: Yeah, there are fish
advisories from the Cape Fear and we did collect sediment
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and surface water sampling, but we found that the
contamination that's in the river isn't coming from the
site. There is existing fish advisories, though.
MR. MATTISON: I believe the fish advisory is for
essentially everything east of 95. But that's not site
related.
MS. SORG: Okay, got you.
MR. TOLLIVER: Anyone else?
MS. SORG:'I think in the documents, maybe it was
in one of the documents I read, there was a pipeline.
Where is that pipeline located? Is it still in existence?
Does it go, like, under
MS. URQUHART-FOSTER: Are you talking about the
pipe that went from Holtrachem to IP?
MS. SORG: I think that's it. It did some kind
of discharge.
MS. URQUHART-FOSTER: That was excavated in 2008
when we did the clean up at International Paper. I don't
know if we actually found the pipe. I know
MR. GUPTA: Remnants of it.
MS. SORG: Were there any problems when the
tornado hit? Of course, you guys remember Hurricane Floyd
did a lot of damage, but the tornado, it wasn't that far
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from here. That didn't have any effect at all?
MS. URQUHART-FOSTER: Well, the facility has an
ongoing Emergency Response Plan in place. So anytime they
know there's going to be a hurricane coming or tornado we
gear into action to prepare for that. There's been minor
damage throughout the years, but it's all been proactively
contained.
MS. SORG: I just have a couple more questions and
that was, how close on the landfill, since it's going to be
getting well possible waiver, how close to the
groundwater is that landfill? Can you tell me, like, from
the bottom of the landfill to kind of the water table, how
far that is?
MS. URQUHART-FOSTER: The water table at the site
is about ten feet deep, but that water at that level is not
usable. It's not usable for drinking purposes. So they're
going to put in a bottom drainage system and liner to get
to meet the equivalent for the TSCO Waiver.
MS. SORG: And the only thing maybe this is --
did anyone ever follow the workers? When I was looking at
the library today there were, I know, some workers back in
the late 90s had high levels or abnormal levels of mercury
in their urine. Was there any kind of study of health
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study for anybody?
MS. URQUHART-FOSTER: I know there was a lawsuit.
I don't know beyond that. I could ask our ATSDR, Agency
for Toxic Substances and Disease to follow-up on that.
MS. SORG: Okay, great. Thank you.
MR. TOLLIVER: That the last question?
MS. FAIL: My name is Kim Fail. I'm with
International Paper. I had two questions. One of which I
have already asked of Walker, but we'd like to understand
the amount of leachate that's going to be generated from
the site and how it will be disposed of. So that's one
question that we had and I think he answered it for me.
MS. URQUHART-FOSTER: Good, because I can't
answer that. He may know.
MR. JONES: My name is Walker Jones. We don't
anticipate a significant amount of leachate from the
landfill. The bulk of it's going to be sort of should
be some saturation of soils, but we think we can manage
that without waste water treatment. So it will be more of
a collection than haul it off-site for disposal.
MS. FAIL: And my second question was about
the -- I know there was an underground drainage system
proposed as well, potentially proposed for this as well.
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So what are your thoughts on with, you know, the ground
water that pumps down? Where will that go?
MS. DRAPER: Cynthia Draper with Amec Foster
Wheeler. I want to make sure I understand. The
underground system that you're talking about, it goes --
it's a it goes underneath the landfill and it's either a
dual liner system or a leachate collection system. It's an
extra safety feature should the groundwater, for any
reason, come up higher, you get higher than five feet, so
that it could come in contact with the landfill. We want
to avoid that. So this will not be something that would be
generated on a regular basis. And I'm sorry, tell me again
the question specifically?
MS. FAIL: Well, I mean, you're obviously going
to have to draw down the groundwater, right? To keep --
you're saying no?
MS. DRAPER: No, we do not plan to continually
depress that groundwater. For one thing, once you get past
that top ten feet you're about 200 feet of very dense clay.
It's very permeating from your site. You probably know all
about that as well. So we do not plan to draw down the
groundwater any further and put an under drain system just
in the unlikely event it should rise up to the surface.
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MS. FAIL: Thank you.
MR. TOLLIVER: Any other questions?
MS. URQUHART-FOSTER: We appreciate you coming
out. Feel free to let your neighbors know about the
information. We encourage anyone to comment and provide us
feedback on the proposed clean up plan.
MR. TOLLIVER: September 14th, that's the end of
the comment period. So we move forward after that. If you
have any concerns please let one of us know and we'll
answer. That concludes our meeting. Thank you all for
coming and we. look forward to hearing from you.
(The Hearing concluded at 7:45 p.m.)
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STATE OF NORTH CAROLINA )
COUNTY OF PENDER )
CERTIFICATION OF REPORTER
I, TAMARA A. VIOLETTE, Notary Public and Court '
Reporter, have read the foregoing transcript, which was
taken down and transcribed by me for AURELIA RUFFIN &
ASSOCIATES, INC., and I find the contents of same to be
true and correct to the best of my knowledge and belief.
This the 2nd day of September, 2016.
/S/
Notary Public, 20031180184
Page 20
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STATE OF NORTH CAROLINA)
COUNTY OF NEW HANOVER )
CERTIFICATION
I, PETER BROWNE RUFFIN, III Notary Public, Court
Reporter and President of AURELIA RUFFIN & ASSOCIATES,
INC., do hereby certify that the foregoing transcript
constitutes a true and correct record of the testimony
given, the same having been taken down and transcribed by
TAMARA VIOLETTE, Notary Public and Court Reporter on the
date and at the place set forth in the record and before
those persons named therein;
FURTHER, that we are not related to and are not
employed by any of the parties to this action, save and
except for the explicit purpose of taking down the
testimony herein and transcribing same; and that we, in no
way, are interested in the outcome of said litigation;
FURTHER, that the. original of this transcript will be
bound for filing with the Environmental Protection Agency
and will be forwarded to ANGELA R. MILLER, Environmental
Protection Agency, Region 4, 61 Forsyth Street, S.W., 11th
Floor, Atlanta, Georgia 30303.
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WITNESS my hand and notarial seal this the 7th day
of September, 2016.
Notary Public, #19971470080
Page 22
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abnormal (1)
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acceptance (1)
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accepting (2)
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access(1) 8:14
acid (1)5:13
action (13) 4:4,5
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actual(1)13:7
address (2) 7:13
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advisories (2)
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advisory (2)
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anybody (1)
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arrow (1) 9:1
asked (1) 17:9
assessment (1)
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ball (1)3:14
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equivalent (2)
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erosion (1) 11:9
essentially (1)
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established (1)
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evening (1)3:2
event(1)18:23
example (2) 9:11
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excavate(1)
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exists (1) 9:1
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follow (1) 16:20
follow-up (1)
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foregoing (2)
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form (1) 14:5
former (5)6:10
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grant (1) 14:6
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great(1) 17:5
hurricane (4)
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idea (1)13:9
free (1)19:4
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full (1)13:17
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impact (1) 4:7
funded (1) 3:22
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future (3) 7:19
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include (4) 8:6
hand (1)22:1
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harm (1) 8:17
includes (2)
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haul (1)17:20
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gallons (1) 6:6
hazardous (1)
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input (3)3:12
getting (1) 16:10
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high (1) 16:22
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IMO:
Holtrachem Site, Riegelwood, NC
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IMO: Holtrachem Site, Riegelwood, NC
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