INTERIM ACTION
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE
TRIANGLE PACIFIC
SUPERFUND SITE
ELIZABETH CITY, PASQUOTANK COUNTY, NORTH
CAROLINA
Prepared For:
U.S. Environmental Protection Agency Region 4
Supermini) Division
Atlanta, Georgia
Prepared By:
Black & Veatch Special Projects Corp.
1120 Sanctuary Parkway, Suite 200
Alpharetta, Georgia 30009
DCN: 49037-0213-04-A-03031R3
July 2018
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DECLARATION
TRIANGLE PACIFIC SUPERFLND SITE
INTERIM ACTION RECORD OF DECISION
SITE NAME AND LOCATION
The 188-aere Triangle Pacific Corporation Site (Site) is located at 1268 Toxey Road, approximately 5,5
miles southeast of Elizabeth City, in Pasquotank. North Carolina (NC). Hie U.S. Environmental
Protection Agency (EPA) identification number for the Site is NCD087336335,
STATEMENT OF BASIS AND PURPOSE
This decisioji document presents the interim remedy for the Site which was chosen by the EPA in
accordance with the Comprehensive Environmental Response. Compensation, and Liability Act
(CERCLA) of 1980. as amended by the Superfund .Amendments and Reauthorization Act (SARA) of
1986. and. to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). Tliis interim action addresses the most elevated contaminant concentrations in soils on the
Site and the trichloroethylene (TCE) contaminant mass within the groundwater plume associated with
the Site. This decision is based on the Administrative Record for the Site.
The State of North Carolina supports the selected remedy.
ASSESSMENT OF THE SITE
"Hie response action selected in this Interim Action Record of Decision (IROD) is necessary to protect
the public health or welfare or the environment from actual or threatened releases of hazardous
substances into the environment.
DESCRIPTION OF SELECTED REMEDY
The Site is being addressed as a single operable unit. The purpose of this interim remedial action (RA)
is to address two areas with elevated soil contamination located in the former Wastewater Treatment
Plant (WWTP) area, and to address the TCE plume in groundwater beneath the central area ot the Site.
.After implementation of the interim remedy, the EPA will gather additional information to determine
how best to address residual Site contamination. Any residual contamination presenting unacceptable
risk to human health or the environment will be addressed in the final remedy for the Site. The selected
interim action includes the following remedial components described in the April 2018 Feasibility Study
(FS)and April 2018 Proposed Plan:
¦ For contaminated soil, the selected remedy is Excavation and Off-Site Disposal. It includes "hot
spot* removal or excavation of surface soil (up to 1 foot [ft] below ground surface [bgs]) at two
locations, where concentrations of Chemicals of Concern (COCs) drive ecological risk for the Site;
olY-site disposal at a Resource Conservation Recovery Act (RCRA) Subtitle D (solid waste), RCRA
Subtitle C (hazardous waste), or a Toxic Substances Control Act (TSCA) Subtitle D landfill
depending on the characterization of the waste. .After excavation and off-site disposal, confirmation
samples will be collected and the open excavation areas will be backfilled with clean fill.
¦ For contaminated groundwater, the selected remedy is Groundwater Enhanced Bioremediation and
Institutional Controls (ICs), The remedy includes an injection of a liquid amendment (for example.
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3D Microemulsiont or similar) to enhance the biodegradation of chlorinated compounds in the
groundwater via reductive dechlorination. Enhanced biodegradation will be conducted in the area
surrounding monitoring well MW-03 with the objective of accelerating the degradation of
chlorinated COCs (including TC'E) in groundwater mid reduce the concentration below levels that
may represent a risk for potential exposure due to ingestion of drinking w ater.
¦ ICs will be implemented by the State to prohibit residential use and redevelopment of the areas
addressed by this interim action. In addition, restrictive covenants will be implemented to prohibit
potable groundwater use 011 the facility and adjacent impacted properties.
¦ Conduct Five-Year Reviews.
STATUTORY DETERMINATIONS
This interim action is 1) protective of human health and the environment in the short term. 2) intended to
provide adequate protection until a final Record of Decision (ROD) is signed. 3) complies with those
federal mid state requirements that are applicable or relevant and appropriate for this limited-scope
action, and 4) is cost-effective. Although this interim action is not intended to address fully the statutory
mandate for permanence and treatment to the maximum extent practicable, this interim action does
utilize treatment and thus supports that statutory mandate. Because this action does not constitute the
final remedy for the Site, the statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume (T M Y) as a principal element, although partially addressed in this
remedy, will be addressed by the final response action. Subsequent actions are planned to address fully
the threats posed by conditions at this Site. Because this interim action will result in hazardous
substances remaining on-site above health-based levels, a review w ill be conducted to ensure that the
remedy continues to provide adequate protection of human health and the environment within five years
after commencement of the RA. Because this is an IROD. review of this Site and remedy will be
ongoing as the EPA continues to develop remedial alternatives for the Site.
DATA CERTIFICATION C HECKLIST
1
COCs and their respective concentrations
Section 7
2
Baseline risk represented by the COCs
Section 7
3
Cleanup levels established for COCs and the basis
for these levels
Groundwater cleanup levels will be
documented in the final ROD for the Site.
Ecological-risk based soil cleanup levels will
be documented in the final ROD for the Site.
4
How source materials constituting principal
threats will be addressed
Section 12
5
Current and reasonably anticipated future land use
assumptions and current and potential future
beneficial uses of groundwater used in the
baseline risk assessment and the ROD
Section 6
6
Potential land and groundwater use that will be
available at the Site as a result of the Selected
Remedv
Sections 6 and 13.4.1
7
Estimated Capital, annual operation &
maintenance (O&M). and total present worth
costs, discount rate, and the number of years over
which the remedv cost estimates are projected
Section 10
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Key Factors that led to selecting the remedy (i.e.,
describe how the Selected Remedy provides the best
8
balance of tradeoffs with respect to the balancing
Section 10
and modifying criteria, highlighting criteria key to
the decision)
AUTHORIZING SIGNATURE
This remedy was selected by the EPA with concurrence of the North Carolina Department of
Environmental Quality (NCDEQ).
Łfanklin E. Hill; Director
Superfund Division
V
hp
Date
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DECISION SUMMARY
INTERIM ACTION RECORD OF DECISION
TRIANGLE PACIFIC Si PERI UND SITE
ELIZABETH CITY, PASQUOTANK COUNTY, NORTH CAROLINA
Prepared for:
U.S. Environmental Protection Agency Region 4
Superfund Division
Atlanta, Georgia
Prepared by:
Black & Veatch Special Projects Corp.
1120 Sanctuary Parkway. Suite 200
Alpharetta. Georgia 30009
July 2018
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Interim Record of Decision
Table of Contents
1.0 SITE NAME. LOCATION. AND BRIEF DESCRIPTION 1-1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
3.0 COMMUNITY PARTICIPATION 3-1
4.0 SCOPE AND ROLE OF RESPONSE ACTION 4-1
5.0 SITE CHARACTERISTICS 5-1
5.1 SITE OVERVIEW 5-1
5.1.1 Climate 5-1
5.1.2 Site Topography 5-1
5.1.3 Site Geology Hvdrogeologv 5-1
5.2 CONCEPTUAL SITE MODEL..." 5-2
5.3 KNOWN AND OR SUSPECTED SOURCES OF CONTAMINATION 5-3
5.4 NAUTRE AND EXTENT OF CONTAM INATION 5-4
5.4.1 Surface Soil Contamination 5-5
5.4.2 Groundwater Contamination 5-5
5.5 AREA OF CONTAMINATION PROPOSED FOR INTERIM ACTION 5-7
5.5.1 Surface Soil 5-7
5.5.2 TCE in Groundwater 5-7
5.6 NATURAL ATTENUATION EVALUATION 5-8
5.7 GROUNDWATER MODELING 5-8
6.0 CURRENT AND POTENTIAL FUTURE LAND AND WATER USES 6-1
7.0 SUMMARY OF SITE RISKS 7-1
7.1 SUMMARY OF HUMAN HEALTH RISK ASSESSMENT 7-1
7.1.1 Identification of Chemicals of Concem 7-2
7.1.2 Exposure Assessment 7-2
7.1.3 Toxicity Assessment 7-2
7.1.4 Risk Characterization 7-3
7.1.5 Uncertainties 7-4
7.2 SUMMARY OF ECOLOGICAL RISK ASSESSMENT 7-5
7.2.1 Identification of Chemicals of Concern 7-5
7.2.2 Exposure Assessment 7-6
7.2.3 Ecological Effects Assessment 7-8
7.2.4 Ecological Risk Characterization 7-10
7.2.5 Uncertainty 7-12
7.2.6 Conclusions of Ecological Risk Assessment 7-13
7.3 BASIS FOR ACTION 7-14
7.3.1 Surface Soil 7-14
7.3.2 Groundwater 7-14
8.0 REMEDIAL ACTION OBJECTIVES 8-1
9.0 INTERIM CLEANUP LEVELS 9-1
Triangle Pacific IROD i
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Interim Record of Decision
Table of C.'oiitents
10.0 DESCRIPTION OF ALTERNATIVES 10-1
10.1 DESCRIPTION OF REMEDY COMPONENTS 10-1
10.1.1 Remedial .Alternatives for Surface Soil 10-2
10.1.2 Remedial Alternatives for Groundwater 10-2
11.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 11-1
11.1 THRESHOLD CRITERIA 11-1
11.1.1 Overall Protection of Human Health mid the Environment 11-1
11.1.2 Compliance with Applicable or Relevant and Appropriate Requirements 11 -2
11.2 PRIMARY BALANCING CRITERIA 11-3
11.2.1 Long-Term Effectiveness and Pennanence 11-3
11.2.2 Reduction of Toxicity. Mobility, and Volume through Treatment 11 -4
11.2.3 Short-Term Effectiveness 11-4
11.2.4 Implementability 11-5
11.2.5 Cost ". 11-5
11.3 MODIFYING CRITERIA 11-5
11.3.1 State Support Agency Acceptance 11 -5
11.3.2 Community Acceptance 11-6
12.0 PRINCIPAL THREAT WASTES 12-1
13.0 SELECTED REMEDY 13-1
13.1 SUMMARY OF THE RATIONALE FOR THE SELECTED REMEDY 13-1
13.2 DESCRIPTION OF THE SELECTED REMEDY 13-2
13.3 SUMMARY OF ESTIMATED REMEDY COSTS 13-2
13.4 EXPECTED OUTCOME OF THE SELECTED REMEDY 13-2
13.4.1 Available I .and Use .After Cleanup 13-2
13.4.2 Final Clean-Up Levels 13-3
13.4.3 .Anticipated Environmental and Ecological Benefits 13-3
14.0 STATUTORY DETERMINATIONS 14-1
14.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 14-1
14.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS 14-1
14.3 COST EFFECTIVENESS 14-2
14.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT (OR RESOURCE RECOVERY) TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICABLE 14-2
14.5 PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT 14-2
14.6 FIVE-YEAR REQUIREMENTS 14-2
15.0 DOCUMENTATION OF SIGNIFICANT CHANGES FROM PREFERRED
ALTERNATIVE OF PROPOSED PLAN 15-1
16.0 REFERENCES 16-1
Triangle Feci tic IROD i i
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APPENDICES
Appendix A Figures
Appendix B Tables
Appendix C Interim Proposed Plan
Appendix D Letter from North Carolina Department of Environmental Quality Supporting the
Selected Interim Action
Appendix E June 2018 Proposed Plan Public Comments and EPA Responses to Comments
LIST OF FIGURES
Figure 1-1 Site Location Map
Figure 1-2 Site Layout and .Areas of Interest
Figure 1-3 Pasquotank County Zoning
Figure 4-1 Estimated Extent of Surface Soil Removal
Figure 4-2 Estimated Injection Grid for In Situ Enhanced Bioremediation
Figure 5-1 Current Land Use
Figure 5-2 Historical Groundwater Potentiometrie Surface Figure
Figure 5-3 1111R A Conceptual Site Model
Figure 5-4 ERA Conceptual Site Model
Figure 5-5 Groundwater Monitoring Network
Figure 5-6 Summary of Chlorinated YQCs in Groundw ater
Figure 5-7 Chlorinated YOCs in Groundwater Section D-D'
Figure 5-8 Chlorinated YOCs in Groundwater Section E-E'
LIST OF TABLES
Table 5-la Constituents in Soil Above Remedial Investigation Screening Levels
Table 5-lb Constituents in Groundwater Above Remedial Investigation Screening Levels
Table 5-2a Summary of Current Soil Analytical Results for Wastewater Treatment Plant .Area
YOCs and SYOCs
Table 5-2b Summary of Current Soil Analytical Results for Wastewater Treatment Plant .Area
Pesticides PCBs Metals Cyanide
Table 5-3 Well Construction Summary
Table 5-4 Historical Summary of Groundw ater Elevations
Table 5-5a Summary of Groundwater Analytical Results 1998-2012
Table 5-5b Summary of Groundwater YOC Analytical Results 2017
Table 5-6 Natural Attenuation Screening
Table 7-la Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 1 (Active Facility .Area) - Surface Soil
Table 7-lb Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 1 (Active Facility .Area) - Surface and Subsurface Soil
Triangle Pacific IROD
in
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Table 7-lc
Table 7-Id
Table 7-le
Table 7-If
Table 7-lg
Table 7-lh
Table 7-2
Table 7-3
Table 7-4
Table 7-5
Table 7-6
Table 7-7
Table 7-8a
Table 7-8b
Table 7-8e
Table 7-8d
Table 7-8e
Table 7-9
Table 7-10
Table 7-11
Table 7-12
Table 7-13
Table 7-14
Table 7-15
Table 7-16
Table 11-1
Table 11-2
Table 11-3
Table 14-1
Table 14-2
Table 14-3
Table 14-4
LIST OF TABLES (C on't)
Occurrence. Distribution, and Selection of Chemicals; of Potential Concern - Exposure
Unit 1 (Active Facility Area) - Shallow Groundwater
Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 2 (Sitewide) - Surface Soil
Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 3 (Pailin Creek) - Sediment
Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 3 (Pailin Creek) - Surface Water
Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 3 (Pailin Creek) - Fish Tissue (Fillet)
Occurrence. Distribution, and Selection of Chemicals of Potential Concern - Exposure
Unit 3 (Pailin Creek) - Blue Crab Tissue
Non-Cancer Toxicity Data - Oral Dermal
Non-Cancer Toxicity Data - Inhalation
Cancer Toxicity Data - Oral Dermal
Cancer Toxicity Data - Inhalation
Risk and Hazard Summary
Risk and Ha/ard Summary - Hypothetical Future Residential Scenario
Terrestrial Exposure .Area Surface Soil BERA Screening
Terrestrial Exposure Area Surface Water BERA Screening
Aquatic Exposure .Area Surface Water BERA Screening
Aquatic Exposure .Area Sediment BERA Screening
Shallow Groundwater BERA Screening
Terrestrial Exposure Area Surface Soil and Surface Water Exposure Point
Concentrations
Aquatic Exposure .Area Surface Water Exposure Point Concentrations
Aquatic Exposure .Area Surface Sediment Exposure Point Concentrations
Shallow Groundwater Exposure Point Concentrations
Terrestrial Invertebrate Tissue Exposure Point Concentrations
Aquatic Invertebrate Tissue Exposure Point Concentrations
Fish Tissue Exposure Point Concentrations
Ecological Exposure Pathw ays of Concern
Summary of Comparative .Analysis of Soil Remedial Alternatives
Summary of Comparative .Analysis of Groundwater Remedial Alternatives
Cost Comparison Summary of Evaluated Alternatives
EPA Region 4 Recommended I ROD Chemical-Specific ARARs and TBCs
EPA Region 4 Legal Recommended IROD Action-Specific ARARs
EPA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Cost Effectiveness Matrix
Triangle Pacific IROD
IV
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LIST OF ACRONYMS
ABSgi
fraction of contaminant absorbed in gastrointestinal tract
AOC
Administrative Order on Consent
ARARs
Applicable or Relevant and Appropriate Requirements
AWCQ
.Ambient Water Quality Criteria
bgs
below ground surface
BERA
Baseline Ecological Risk Assessment
BRA
Baseline Risk Assessment
BTAG
Biological Technical Assistance Group
CDI
Chronic daily intake
CERCLA
Comprehensive Environmental Response. Compensation, and Liability Act of 1980
(Superfund)
CFR
Code of Federal Regulations
C'OCs
Chemicals of Concern
COPCs
Chemicals of Potential Concern
CSF
cancer slope factor
CSM
conceptual site model
DCE
diehloroethene
CTE
central tendency exposure
DDT
dichlorodiphenyltrichloroethane
DO
dissolved oxygen
EPA
U.S. Environmental Protection Agency
EPC
Exposure Point Concentrations
ERA
Ecological Risk Assessment
ESI
Expanded Site Investigation
vF
degrees Fahrenheit
FS
Feasibility Study
ft
feet
HHRA
Human Health Risk Assessment
HI
Hazard Index
IIMW PAHs
high molecular weight polycyclic aromatic hydrocarbons
HQ
Hazard Quotient
HRS
Hazard Ranking System
IMAC
interim maximum allowable concentration
IROD
Interim Action Record of Decision
ICs
Institutional Controls
II" R
inhalation unit risk
LMW
low molecular w eight
LOAEL
lowest observed adverse effects level
MCLs
Maximum Contaminant Levels
Hg L
micrograms per liter
mg day
milligrams per day
mg kg
milligrams per kilogram
nig kg-day
milligrams per kilogram per day
mg L
milligrams per liter
NC
North Carolina
NC 2L standards 15 A NCAC 02L Groundwater Quality Standards
NCAC
North Carolina Administrative Code
NCDENR
North Carolina Department of Environment. Health, and Natural Resources
Triangle Pacific I ROD
v
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LIST OF ACRONYMS « oirn
NCDEQ
North Carolina Department of Environmental Quality
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NOAEL
no-observed adverse effects level
NPL
National Priority List
NPW
net present w orth
OBG
O'Brien & Gere Engineers. Inc.
O&M
Operation and Maintenance
ORP
oxidation reduction potential
OS HA
Occupational Safety and Health Administration
PAH
polyeyelie aromatic hydrocarbon
PCBs
pol> chlorinated biphenyls
pH
hydrogen ion concentration
POEs
Points of Exposure
PRO
preliminary remedial goals
PTW
principal tlireat waste
RA
Remedial Action
RAGS
Risk Assessment Guidance for Superfund
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
RiC
reference concentration
RIB
reference dose
R1
Remedial Investigation
RME
reasonable maximum exposure
ROD
Record of Decision
SARA
Superfund .Amendments and Reauthorization Act
SF
slope factor, expressed as (nig kg-day)"1
Site
Triangle Pacific Corporation Site
SSI
Screening Site Investigation
svoc
semi-volatile organic compound
TAL
Target Analyte List
TBC
To Be Considered
TCE
trichloroethylene
TCL
Target Compound List
TCOM
TCOM LP
TM V
toxicity, mobility, or volume
TOC
total organic carbon
TRY
toxicity reference value
TSCA
Toxic Substances Control Act
UCL
Upper Confidence Limit
USACE
U.S. Army Corps of Engineers
YOC
volatile organic compounds
VVTP
waste water treatment plant
Triangle Pacific I ROD
VI
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INTERIM ACTION RECORD OF DECISION
TRIANGLE PACIFIC Sl l'ERFVM) SITE
ELIZABETH CITY, PASQUOTANK COUNTY, NORTH CAROLINA
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
1.0 SITE NAME, LOCATION, AND BRIEF DESCRIPTION
The U.S. Environmental Protection Agency (EPA) identification number for the Triangle Pacific
Corporation Site (Site) is NCD087336335. The 188-aere Site is located at 1268 Toxey Road,
approximately 5.5 miles southeast of Elizabeth City, in Pasquotank. North Carolina (NC). Hie Site is
situated on the southern portion of a small peninsula formed by the Pasquotank River on the east and
Newbegun Creek on the south (Figure 1-1). A small tributary of New begun Creek called Pail in Creek
borders a portion of the west side of the Site. The surrounding area consists of mostly residential
communities, with some being agricultural.
The lead agency for the Comprehensive Environmental Response. Compensation, and Liability Act of
1980 (CERCLA) regulatory response at the Site is EPA. Hie North Carolina Department ot
Environmental Quality (NCDEQ) is the support agency. Environmental investigations and response
actions undertaken at the Site to date have been funded by the CBS Corporation and Armstrong Wood
Products. Inc.. the successor to Triangle Pacific Corporation. Environmental cleanup of the Site will be
funded by them as well.
A portion of the 188-aere Site is actively used in manufacturing operations. The remaining Site area is
comprised of open land with low herbaceous vegetation or w oodbinds. "Hie adjacent w aterfront property
adjoining the Pasquotank River (northeast, east, and southeast of the Site) and New begun Creek
(southeast and east of the Site) is occupied by single-family residential dwellings on large lots. This
area of residential development was also formerly a portion of the Weeks vi lie Naval Air Station. The
nearest residence in these areas is approximately 300 feet (ft) from the Site, across Pailin Creek to the
west. Land uses to the w est, northw est, and north of the former Navy base are chiefly agricultural,
including row crops, although a former agricultural area along the w est bank of Pailin Creek has been
developed for residential properties. The U.S. Coast Guard airfield and the Elizabeth City Municipal
Airport are located approximately 3 miles northw est of the Site.
Pasquotank County has zoned most of the active areas of the Site for industrial use with the southern
portion of the Site (which includes a Landfill) zoned for residential use (Figure 1-2 and Figure 1-3).
There is also a small area across Pailin Creek which contains the former rail spur serving the Site that is
zoned residential. Projections of future land use made by Pasquotank County are like the current zoning
designations, except that the area on the southern portion of the Site is expected to be rezoned as
commercial or rural agricultural.
Triangle Pacific IROD
1-1
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2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1943. the U.S. Government acquired land containing the Site, which the Navy subsequently
developed into the Weeksville Naval Air Station, The naval Air Station was used for seaplane
maintenance mid repair and operated as a dirigible (lighter-than-air craft or "blimp") Airdock. The Navy
continued its operations until 1960. During the dirigible base operations, the Navy constructed two
large the hangars to facilitate the construction and testing of the aircraft. One of the hangers is still
standing and located on the Site. In 1964. the LIS. Government sold the parcel containing the Site to the
NC State Port Authority, who in turn, sold the parcel to Westinghouse in 1967. Westinghouse thereafter
sold the majority of the base, retaining what is now referred to as the "Site" for its use for the
manufacture of wooden kitchen and bathroom cabinets. Westinghouse converted the former hangar into
its manufacturing plant. In 1977. Westinghouse sold its cabinet-making business, including the Site, to
Triangle Pacific Corporation, which continued to manufacture cabinets at the Site until 1996. Triangle
Pacific Corporation then sold most of the property to TCOM LP (TCOM). who now manufactures and
tests aerostat launching systems. TCOM has sold a portion of the Site to Rankin Real Estate, who leases
it to AMS Corporation for use in the deployment of airship advertising.
From 1975 to 1996 the Site is known to have generated two separate hazardous waste streams from the
manufacturing of w ooden cabinets, as w ell as one non-hazardous waste stream. The w aste streams w ere
created from spent non-halogenated solvent based toner and lacquer thinner and lacquer dust. The toner
and lacquer thinner reportedly contained various chemicals including methyl ethyl ketone, toluene,
acetone, isobutanol. and several metals including cadmium and arsenic.
From 1996 to the present, much of the Site is unused by the current owners TCOM. and most of the
current operations are concentrated on the northeastern portion of the Site (Figure 1-1). The Site is
dominated by a hangar building, which is used by TCOM for office space, storage, and inflation of
aerostats. To the north and east of the hangar are concrete aprons that represent former taxi ways and
runways constructed by the Navy and currently used by TCOM for equipment storage, parking, and
testing of aerostat systems.
Across the street to the w est of the hangar and north of the main access road is a building TCOM
currently uses for the assembly and testing of launching platforms for aerostats. This building was
constructed in 2009. and overlies the former manufacturing building (Building 402). and drum storage
pad. which w as located to the w est of this building. Further to the w est of the hangar is another
building, primarily used by AMS Corporation as office and storage space. West of the hangar and to the
south of the main access roads are several older structures, including a water tower, former cistern,
boiler house, and former public works shop building and fueling station. The water tower and fueling
station are currently used by TCOM. "Hie former cistern is used for storage by TCOM.
The boiler house is not in use and is overgrown with vegetation and in poor condition. The area to the
south of the boiler house is a former coal storage area. The area has a low mound of coal remnants and
soil mid is overgrown with vegetation. The former public works shop building is currently used for
storage by TCOM. The area north of the former public works shop building is a concrete apron with
abandoned pipe penetrations. This area formerly contained a fire station, a transportation shop, and a
public works garage, as well as a waste oil tank. Within the overgrown area south of the former public
works shop building is the foundation of a fonner laundry building. To the west of the former laundry
building is a concrete apron and equipment pad. The apron is contiguous with the foundation for the
public works storage building, and formerly contained the public works office building. The equipment
pad is a remnant of a former sanitary sewage pump house. Further to the west of these areas, the Site is
largely unused and is overgrown with trees. Remnants of fonner concrete aprons are visible, as are a
Triangle Pacific I ROD
2-1
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former refueling area used by the Navy, Currently, this area is overgrown and covered with piles of soil
and miscellaneous debris. To the south and west of these aprons are the former barracks, swimming
pool, locker room, and the abandoned railroad spur that formerly served the Site.
To the south of the hangar, the Site is largely unused by TCOM and consists of open grassland, forest,
and swamp, which have overgrown features formerly used by Triangle Pacific Corporation and the
Navy. This includes a former blimp tethering area, as well as a closed landfill. This landfill was
reportedly used by Westinghouse and Triangle Pacific Corporation from 1972 - 1979. for the disposal of
w astes generated during the production of w ood cabinets. A map obtained from the Navy in 1990. as
well as the U.S. Geological Survey topographic map for the Site, labels the landfill area as "sewage
disposal." Historically, the landfill was mowed, but mow ing has not been continued in recent years, and
the area is overgrown with trees, shrubs, and bunch grass.
Northwest of the landfill is an area that contains the former waste water treatment plant (WWTP) mid
incinerator used by the Navy, These structures are overgrown and in disrepair. To the west of these
structures are two earthen pits of uncertain usage, but presumably associated with the former WWTP.
"Hie area surrounding these pits contains a variety of metal and concrete debris, and is the area from
w hich the remnants of approximately 30 to 40 steel drums and surrounding soil w ere removed as part of
the field investigation activities in 2011.
During the Remedial Investigation (RI). the above-mentioned areas w ere divided into several broad
areas based on use to facilitate the EPA's response actions in addressing the cleanup of various media
contaminated by the former naval facility and w ood cabinet treating and preserving operations. These
areas include the storage tank area, wooded Area northwest of the landfill. WWTP and incinerator, on-
site landfill, coal storage area. Field North or wooded area. Former Fuel Island .Area. Areas surrounding
the Blimp Hangar. and Pailin Creek (Figure 1-2).
Regulatory History;
Several investigations have been performed at the Site, beginning w ith the first phase of assessment
performed in 1987. mid culminating with the investigations conducted as part of the RI in 2011 and
2012. These investigations have been performed under the direct supervision or oversight of EPA and
the NCDEQ (or its precursor agency. North Carolina Department of Environment. Health, and Natural
Resources [NCDENR]), Each investigation was developed using information obtained from prior
investigations and has been targeted to areas of the Site considered of most concern. The following
provides a brief overview of these investigations;
¦ November 1987 Preliminary Assessment - The NCDENR. Division of Health Services performed
the preliminary assessment, assigned the Site a medium priority for assessment. Furthermore, the
NCDENR, Division of Health Services determined that a site inspection w as needed to assess if the
Site posed a threat to human health and the environment.
¦ June 1990 Phase I Screening Site Investigation (SSI) - The Phase I SSI was performed by
Greenhome & O'Mara. Inc., under the direction of the NCDENR. The SSI identified two hazardous
waste streams from manufacturing operations (i.e.. spent non-halogenated solvent-based toner and
lacquer thinner, and lacquer dust). "Hie investigation also identified the presence of the on-Site
landfill (Landfill .Area). The Phase I SSI also identified that the Site was located near wetlands, as
well as the Pasquotank River and New begun Creek, and that groundwater in the region was used as a
drinking water source. Based on the potential for surface w ater mid groundwater impacts, in
addition to potential worker exposure, the Site was identified as representing potential risk to human
health mid the environment and was recommended for a high priority.
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" December 1990 Phase II SSI - This investigation was also performed by Greenhome & O'Mara.
Inc.. under the direction of the NCDENR and included a site inspection, interviews, and
environmental sampling. The site inspection and interviews prov ided more detail on operations at
the Site and identified the presence of the Storage Tank Area and Boiler House. Samples were
collected from various media to assess the potential for environmental releases including two surface
soil, two surface water. three sediment, and three groundwater samples. These samples were
analyzed for target compound list (TCL) volatile organic compounds (YOCs) and semi-volatile
organic compounds (SYOCs), and target analyte list (TAL) metals and cyanide. "Hie analytical
results for these samples indicated the presence of various constituents in environmental media.
Based on these results, an Expanded Site Investigation (ESI) was recommended.
¦ 1992 Drum Removal - Contractors for the U.S. Army Corps of Engineers (US ACE) reportedly
removed 33 drums of material that were staged at the Landfill. Information concerning the contents
of these drums has not been made available by the US ACE, and no information was found in
NCDENR files.
¦ December 1995 Supplemental Screening Inspection - This inspection was performed by the EPA. at
the request of the NCDENR Site Management Branch. Waste Management Division, and included
the collection of four surface soil and sediment samples. These samples w ere analyzed for TCL
YOCs. SYOCs. pesticides. pol\chlorinated biphenyls (PCBs), TAL metals and cyanide. No
conclusions or recommendations were prov ided in the Supplemental Screening Inspection Report,
¦ September 1998 ESI - Based on the findings of the previous investigations, and under the terms of
an Administrativ e Order on Consent (AOC) entered with the EPA. CBS Corporation and Armstrong
Wood Products. Inc.. conducted an ESI to develop the data needed to rank the Site, using the Hazard
Ranking System (HRS). for possible inclusion on the National Priority List (NPL), I "nder the terms
of that AOC, S&ME. Inc. performed the ESI on behalf of CBS Corporation and Armstrong Wood
Products. Inc.. in 1997 and 1998. In scoping the ESI. sample locations were selected, with input
from the EPA and NCDENR. from Site areas identified in prior screening investigations to provide
the data to assess whether these areas were impacted. Specifically, these included collection of soil
samples from a background location, the Tank Storage Area Drum Storage Area. Boiler House.
Stacker Building, Tar Stained Soil .Area, and Landfill. Six monitoring wells were installed and
sampled including a background location. Surface water and sediment samples were collected from
five locations on Pail in Creek. Two sediment samples were also collected from Newbegun Creek.
Under an agreement with EPA. NCDENR used the ESI data to generate a HRS score for the Site.
Although EPA determined the site qualified for listing on the NPL. EPA decided not to list the site.
Instead the site has been addressed as "NPL equivalent".
¦ 2011 to 2014 RI - three phases of Site characterization were performed between October 2011 and
February 2012. October and November 2012. and September 2014. The data from these
investigations are compiled and summarized in the RI Report. These investigations focused on
discrete areas of the Site identified in the AOC. as well as areas subsequently identified in
discussions with EPA (Figure 1-2):
• Storage Tank .Area
• WWTP .Area
• Landfill
• Boiler House Coal Storage Area
• Drum Storage Pad
• Stacker Building
• Tar Stained Soil .Area
• Pailin Creek,
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3.0
COMMUNITY PARTICIPATION
The RI Report, Feasibility Study (FS) document. Interim Action Proposed Plan, and all other pertinent
documents for the Site were made available to the public in April 2018 and also in early May 2018. All
of these documents can be found in the Administrative Record and the information repositories
maintained at EPA Superfund Record Center in Region 4 and at the Pasquotank-Camden Library. 100
East Colonial Avenue. Elizabeth City. NC 27909.
The Agency placed an ad in the Herald newspaper on April 24. 2018 to announce the time. date, and
location of the Interim Action Proposed Plan meeting and to inform the public that the Administrative
Record Info mi at ion Repository was available for the public's review. The 1-page Interim Action
Proposed Plan Fact Sheet was mailed to the public on May 1. 2018 and an additional 100 fact sheets
w ere hand distributed the week of May 8, 2018. This fact sheet is based on the April 2018 Interim
Action Proposed Plan. The Interim Action Proposed Plan meeting was held on May 8. 2018 at the
Pasquotank-Camden Library. The Community Involvement Plan was completed in May 2018.
At the Interim Action Proposed Plan meeting, representatives from EPA and NCDEQ answered
questions regarding the findings of the RI and the proposed remedial alternative for the Site. The 30-day
public comment period ran from May 8 through June 7. 2018. EPA's responses to the comments
received during the Interim Action Proposed Plan public meeting are included in the Responsiveness
Summary, which is part of this Interim Action Record of Decision (IROD). Comments received during
the public comment period are summarized and addressed in Appendix E.
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4.0 SCOPE AND ROLE OF RESPONSE ACTION
The Triangle Pacific Corporation Site is not on the NPL; however, the EPA is managing the Site as an
"NPL-equivalent" site and is following the CERCI.A remedial process.
The Site is being addressed as a single operable unit. The EPA will conduct an interim action to address
two areas with elevated soil contamination that present an ecological risk located in the former WW TP
area (Figure 4-1). .Any remaining residual soil contamination after this interim remedy still presenting
unacceptable ecological risk will be addressed in the final remedy for the Site.
Groundwater beneath the Site is classified as a current and potential source of drinking water. .An
interim action will be conducted to address the YOC (trichloroethylene [TCE]) contaminant mass within
the groundw ater plume beneath the central area of the Site prior to completion of the groundw ater
investigation (Figure 4-2). .After the bioremediation treatment remedy (selected for this interim
remedy), any remaining residual TCE or other Chemicals of Concern (C'OCs) in groundwater
contamination presenting unacceptable risk or above federal or state drinking water standards will be
addressed in the final remedy for the Site.
Tliis IROD describes the interim remedial action chosen as the short-term remediation plan for the Site.
Following implantation of the interim remedial action, a final Record of Decision (ROD) will be
pursued. The soil and groundwater interim actions will be consistent with the final action selected for
the Site. The final ROD will address any remaining unacceptable risks posed to human health and the
environment not addressed by this interim action. The final ROD must satisfy the follow ing. as
indicated in CERCLA:
¦ provide long-term protection of human health and the environment;
¦ comply with Applicable or Relevant and Appropriate Requirements (ARARs):
¦ fully address the principal threats posed by the site; and
¦ address the statutory preference for treatment that reduces the toxicity, mobility, or volume (T M Y)
of wastes.
The current and reasonably anticipated future use for most of the Site is industrial. Should land use
change, further investigation, a supplemental human health risk assessment, and additional response
actions may be required. The southern portion of the Site where the Landfill is located is zoned for
residential use. and is expected to be rezoned for commercial or rural agricultural use before the final
ROD.
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5.0 SITE CHARACTERISTICS
All appropriate environmental media (surface soils and groundwater) as well as other characteristics of
the Triangle Pacific Site are discussed in this section. Other than for evaluation as a component of the
human health and ecological conceptual site models (CSM). characteristics of subsurface soils, surface
water, and sediment are not described in detail in this IROD. These media were determined to not
present current unacceptable human health risks, however a small area does present unacceptable
ecological risks,
5.1 SITE OVERVIEW
"Hie majority of the Site is currently zoned for industrial use, but only a portion of the 188 acres is
actively used for manufacturing operations. Much of the Site is open land with low herbaceous
vegetation or woodlands. The adjacent w aterfront property adjoining the Pasquotank River (northeast,
east, and southeast of the Site) and New begun Creek (southeast and east of the Site) is occupied by
single-family residential dwellings on large lots. This area of residential development was also formerly
a portion of the Veeksville Naval Air Station. Hie nearest residence in these areas is approximately
300 ft from the contaminated soil in the WWTP area, across Pail in Creek to the west. Land uses to the
west, northwest, and north of the former Navy base are chiefly agricultural, including row crops,
although a former agricultural area along the w est bank of Pailin Creek has been developed for
residential properties (Figure 5-1). 'Hie U.S. Coast Guard airfield and the Elizabeth City Municipal
Airport are located approximately 3 miles northw est of the Site.
Pasquotank County has zoned most of the active areas of the Site for industrial use with the southern
portion of the Site (w hich contains the Landfill) zoned for residential use. There is also a small area
across Pailin Creek which contains the former rail spur serving the Site that is zoned residential.
Projections of future land use made by Pasquotank County are similar to the zoning designations, except
that the southern portion of the Site is expected to be rezoned commercial or rural agricultural.
5.1.1 Climate
In tl le Elizabeth City area, the mean annual precipitation is approximately 46.97 inches. The mean lake
evaporation is approximately 55 inches. Lying in the coastal plain, the Site is subject to severe storms,
such as hurricanes, which can affect and alter Site conditions on a periodic basis. "Hie average annual
temperature near the Site is 60,0 degrees Fahrenheit (':'F). with the annual average ranging from 50.6 F
to 69,4: F, Daily extremes range from a low of-3,0 F in December, to a high of 107,0° Fin July.
Average daily temperatures in January. April. July, and October are 42.4 . 59.1, 79.2 . and 62,6 F,
respectively. January is the coldest month, and July is the hottest month. The State Climate Office of
North Carolina at North Carolina State University provided the information about climatic conditions in
the vicinity of the Site (Elizabeth City Airport, approximately 3 miles northwest of the Site).
5.1.2 Site Topography
The topography of the site is flat with no significant topographic relief. Site elevations range between
6 and 12 ft above mean sea level. The majority of the surface runoff from the Site is toward Pailin
Creek.
5.1.3 Site Geologv/Hvd rogeology
Hie Site is underlain by Quaternary surficial deposits and the Yorktown Formation. These two
formations are continuous throughout most of Pasquotank County. The surficial deposits range from
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30 ft thick in the northern part to 60 ft thick in the southern pait of the County, but may be as much as
140 ft thick along the Pasquotank River and parts of Albemarle Sound. These deposits consist of
interbedded sands and clays deposited in marine and estuarine environments, similar to those currently
present in the area.
The surficial deposits unconformably overlie the Yorktown Formation, which ranges in thickness from
135 ft in northern Pasquotank County, to 185 ft in the southern part of the county. The type section for
the Yorktown Formation includes four members, regionally including the bottom Member consists of
pebbly, coarse-grained sand overlying shell), fine-grained sand. This in turn is overlain by a very fine-
grained sandy clay with shell layers. The uppermost Member consists of a sandy shell hash and semi-
indurated eoquina. The Yorktown pinches out to the west, and thickens to the east.
The RI included investigation of the surficial groundwater, which was encountered at depths ranging
from 3 to 11 ft below ground surface (bgs). A recent potentiometric map is included as Figure 5-2. The
groundwater beneath the Site is a current and potential source of drinking water (Class GA or Class
GSA under 15A North Carolina Administrative Code [NCAC] 02L.0201), The groundwater is
uncontlned. and has a low gradient, with How across the Site generally to the west and south, toward
Pailin and Newbegun Creeks, although potentiometric surfaces developed for the RI showed a complex
and variable flow direction that results in limited How overall. Water levels in Pailin and Newbegun
Creeks are influenced by tides, and fluctuate significantly. "Hie northern portion of the Site has many
paved areas where infiltration is limited. Precipitation in these areas will tend to run olYthe paved
surfaces and into storm sewers that will rapidly cany the water to Pailin and Newbegun Creeks.
Hydraulic conductivity w as calculated from instantaneous discharge (slug) tests performed during the
supplemental groundwater investigation in September-October 2017. Overall, hydraulic conductivity
measurements were consistent with expectations for the lithology observed during drilling. Measured
hydraulic conductivities ranged from 0.0001 to 0.001 centimeters per second, which is consistent with a
sand and silty sand.
5.2 CONCEPTUAL SITE MODEL
A CSM identifies the mechanisms and pathways by which human and ecological receptors may come
into contact with chemicals at or migrating from contaminant source areas. The CSM identifies the
sources of contamination, the mechanisms by which contaminants migrate are transported, the routes of
exposure, and the receptors under current and future land use scenarios potentially contacting
environmental media. Figure 5-3 provides the Site's human health CSM and Figure 5-4 provides the
Site's ecological CSM. The information presented on Figures 5-3 and 5-4 is based on Site specific
historical, chemical, and hydrogeologieal information as well as an identification of current and future
human and ecological receptors potentially contacting environmental media in Site soil and
groundwater, and in off Site media w ithin the adjacent Pailin Creek and its headw aters. The CSM is
supported by the geological and hydrogeologieal characteristics, the nature and extent of contamination,
the fate and transport of the COCs. and the behavior of chlorinated YOCs. polycyclie aromatic
hydrocarbons (PAHs). PCBs. pesticides, and metals in the environmental media associated with the Site.
The CSMs summarize the general conclusions regarding fate and transport of COCs in surface soil (0-1
ft bgs), subsurface soil (0-10 ft bgs). shallow groundwater, surface water, and surface sediment (0-0.5 ft
bgs). file final ROD CSM is expected to be fully developed to characterize all contaminated site media
and pathways.
The CSMs considered both primary mid secondary contamination sources identified based on review of
historical Site manufacturing activities and analytical data from Site investigations. Primary sources
Triangle Pacific IROD
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included product or waste potentially related to historical operations that are present at the coal storage
area and the landfill. Secondary sources include residual constituents found in on and oft-site media.
The fate and transport of the chemicals from source media were considered to identify media that may
receive Site-related chemicals. Contaminant pathways evaluated include:
" Transport of constituents to soils, sediment and surface water via surface water runoff - Constituents
from current or former active areas of the facility may impact other Site soils, sediments, and surface
water through transport via runoff,
¦ Infiltration percolation of constituents to subsurface soil and groundwater - Potential recharge from
precipitation and minor topographic differences throughout the Site. This is more than likely
localized depressions where runoff can move to, accumulate and more readily move into the
subsurface than elsewhere
¦ Discharge of groundwater to surface water - Once constituents have reached Site groundwater via
infiltration percolation, these constituents could discharge to Pail in Creek, primarily via shallow
groundwater. Contaminants reaching groundwater could be adsorbed to aquifer materials,
biodegrade. be volatilized from the groundwater surface or otherwise be attenuated before being
transported to surface water.
¦ Stiff ace water transport of constituents - Once constituents have reached Pail in Creek surface water,
they are capable of being transported to other portions of Pailin Creek due to its tidal nature.
Dissolved phase constituents in surface water have the potential to partition into surface sediment of
Pailin Creek.
¦ Transport of constituents from sediments in surface water - Once constituents have reached Pailin
Creek sediment, they can be potentially transported to other portions of Pailin Creek due to its tidal
nature.
¦ Wind Dispersion - Constituents in surface soil can be transported throughout the Site as fugitive dust
particles.
¦ Volatilization - YOCs present in surface soil can volatize to the ambient air at the Site.
Consistent with the CSMs. contaminants that were released from sources have migrated through the
soils and into the shallow water table and via overland flow groundwater discharge into surface water
and sediment. The risk assessments evaluated all of these potentially complete exposure pathways and
ultimately determined that the Site contamination that presents unacceptable human health and
ecological risks primarily resides in the surface soil and shallow groundwater system.
5.3 KNOWN AND/OR SUSPECTED SOURCES OF CONTAMINATION
Little is known about the storage, handling, and disposal of hazardous materials and w astes at the Site
prior to 1975. From 1975 to 1996. the Site is known to have generated two separate hazardous waste
streams from the manufacturing of wooden cabinets, as w ell as one non-hazardous waste stream. The
hazardous waste streams, regulated by state and Federal regulations under the Resource Conservation
and Recovery Act (RCRA) of 1976. as amended, included spent non-halogenated solvent-based toner
and lacquer thinner, and lacquer dust. The toner and lacquer thinner reportedly contained methyl ethyl
ketone, toluene, acetone, isobutanol. cadmium, and arsenic. "Hie toner and lacquer thinner also
contained methanol and isopropyl acetate. Neither identified waste stream contained chlorinated
alkenes (e.g.. TCE or tetrachloroethylene) or chlorinated benzenes.
The toner and lacquer thinner were generated from the finishing and painting of the cabinets, and these
two wastes were blended together and drummed. At the time of a December 1990 Site investigation, the
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drums! were stored outside the hangar on a concrete pad until collected by the Oldover Corporation of
Cascade, Virginia, Pre-1980 handling of this waste stream is not documented.
The lacquer dust was generated from ova-spray of the lacquer paint and toner in the spray booths. These
spray booths were scraped daily of overspray build-up. Until 1987, the lacquer dust was sent to the
Pasquotank County Landfill; after 1987, this dust was incinerated in the boiler house on Site.
A non-hazardous w aste stream of saw dust and scrap w ood w as generated from sanding and cutting the
wooden cabinets. This waste stream was reportedly ground and transported to the boiler house for
incineration. Soil borings installed in the on-site landfill during the first phase of Site characterization
contained a layer of w oody debris that may have included similar material. Based on previous reports
that indicate the landfill was used from 1972 to 1979. it appears that at least some this waste was
disposed in the landfill: however, no documentation is available regarding specific waste materials or
disposal practices.
The former WW IP mid refuse incinerator used by the Navy are located southwest of the main
production area. Operation of the WWTP stalled in the 1940s and continued into the 1990s, while the
Site was owned by Triangle Pacific Corporation. The WWTP consisted of several treatment units that
are still in place. On the east side of the WWTP. a rectangular concrete pad with an overlying manifold
is suspected to be a former sludge dry ing bed. In the middle of the WWTP area is an incinerator used by
the Navy. Two earthen pits are located on the west side of the WWTP. Visual observations at the
surface, in addition to cores from borings installed in this area for the Site characterization do not
suggest that burial of debris occurred in this area.
The source of TCE contamination in groundwater is unknown. TCE is a manufactured organic chemical
that is not naturally occurring. TCE was used commonly as an industrial solvent, dry-cleaning agent,
and degreaser until the 1980s, when concerns regarding toxicity resulted in its replacement with other
chlorinated and non-chlorinated solvents. The most likely source of TCE at the Site w ould have been as
a solvent, cleaner, mid or degreaser used in maintenance and repair activities. Historically, the U.S.
military also used TCE as a fire fighting agent and cleaner for aircraft.
5.4 NATURE AND EXTENT OF CONTAMINATION
Data supporting the RI were obtained during an ESI performed in 1998 and three phases of Site
characterization performed between October 2011 and February 2012. October and November 2012, and
September 2014. All of these investigations focused on discrete areas of the Site identified in the AOC.
as well as areas subsequently identified in discussions with the EPA (Figure 1-2):
¦ Storage Tank .Area:
" Wastew ater Treatment Plant Area;
¦ Former Landfill;
¦ Boiler House Coal Storage .Area;
¦ Drum Storage Pad;
¦ Stacker Building;
¦ Tar Stained Soil .Area; and
¦ Pailin Creek.
These investigations included the collection of samples from soil and groundwater from all areas of the
Site; surface water, sediment, and biota from Pailin Creek; and terrestrial invertebrates from selected
Triangle Pacific 1ROD 5-4
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areas of the Site. Based on evaluation of this data in the Rl Report, the following is a summary of the
Site-related contamination that presents unacceptable human health and or ecological risks.
5.4.1 Surface Soil Contamination
Several metals (arsenic, barium, cadmium, copper, lead, selenium, vanadium and zinc) were detected at
concentrations exceeding ecological screening levels at locations across the Site. Both cadmium and
arsenic were identified as constituents in the lacquers formerly handled at the Site. Organic chemicals
that exceeded ecological screening levels included total PCBs, high molecular weight PAHs (high
molecular weight polyeyclie aromatic hydrocarbons [HMW PAHs]), and 4.4'-
dichlorodiphenyltrichloroethane (DDT). The highest concentrations of metals and the organic chemicals
were generally from two locations (BH-18 and BH-26) in the former WW TP Area. Soil results are
presented in the RI (O'Brien & Gere Engineers, Inc. [OBGj. 2015). A summary of constituents in soil
above screening levels is presented in Table 5-la.
PCBs are a class of manufactured, non-naturally occurring chemicals that w ere used most commonly in
dielectrics, heat transfer, and hydraulic fluids where there was a significant risk of combustion.
Production of PCBs was discontinued in the U.S. in 1977. In 1978. uses of PCBs were strictly limited
under the Toxic Substances Control Act (TSCA). PCBs were not a component of previous cabinet
manufacturing activities at the Site. PCB Aroclors 1248. 1254. and 1260 were detected in surface soil at
concentrations above human health and ecological screening levels at various locations across the Site.
"Aroclor" was a trademark for a commercial blend of various PCB congeners, and different .Aroclors
were designed for specific viscosities and other properties. .Aroclors 1254 and 1260 were most
commonly associated with dielectric fluids for electrical transformers. Aroclor 1248 was more
commonly associated w ith heat transfer and hydraulic fluids. The highest concentration of PCBs (110
milligrams per kilogram [nig kg]) was in the former WWTP .Area (BH-18). PCB risk can be further
characterized with the use of congener analysis; w hen PCBs are likely weathered, as on this site,
congener analysis with TEQ TEF may show a lower toxicity.
HMW PAHs are natural components of coal. oil. and tar. and can also be produced by the partial
combustion of organic materials, coal, or oil. Potential sources of PAHs at the Site include asphalt
roads, roofing tar. coal, motor oils and fuels, and other petroleum-containing products. These HMW
PAHs at the Site exceeded ecological screening levels with the highest concentration (765 nig kg) in the
former WWTP .Area at BH-26.
4.4--DDT is a pesticide that was in widespread agricultural and general use prior to being banned in
1972. It was found at concentrations exceeding ecological screening levels at several locations across
the Site. It was not a component of previous cabinet manufacturing activities at the Site. Its presence is
likely attributable to aerial spraying of the surrounding agricultural fields, potentially for mosquito
control, or possibly localized historical spraying at the Site for pest control. The highest concentrations
of 4.4"-DDT (5.5 mg kg max) were in the former WWTP .Area at locations BH-18 and BH-26.
5.4.2 Groundwater Contamination
Groundwater beneath the Site is classified as a current or potential source of drinking water (EPA
Class II). North Carolina classifies groundwater beneath the Site as a potential source of drinking water
and expects such groundw ater to be remediated for beneficial reuse (Class GA or Class GSA under 15.A
North Carolina Administrative Code [NC'AC] 02L.0201).
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Contaminants detected in the groundwater exceeding 15A NCAC 02L Groundwater Quality Standards
(NC 2L standards) included YOCs. metals, and pesticides. Groundwater results are presented in Tables
5-5a and 5-5a. A summary of constituents in groundwater above screening levels and MCLs are
presented in Table 5-lb
A combination of data collected from field screening and laboratory analysis of groundw ater samples
collected from monitoring wells has identified the presence of a diffuse and extensive TCE plume in
groundw ater beneath the central area of the Site. The levels range from below detection up to at least
290 micrograms per liter (fig L). The contaminant mass is hugely within a cleaner, coarser, and likely
more transmissive sand present at a depth of approximately 15 to 25 ft bgs. The observed distribution of
the chlorinated YOCs. with most of the detections and highest concentrations below 15 ft bgs and
limited detections above this depth, suggest these TCE releases occurred historically, and maybe derived
from widespread, low- concentration releases to the ground surface, and do not have a continuing
source. Much of the area of impact is impaved: the shallow" groundwater will receive direct recharge
from rainfall in this area. TCE is somewhat soluble in water and is likely to be leached rapidl y from the
soil into groundwater with the percolation of rainwater. Overtime, in the absence of continued release,
or with high residual concentrations in soil, these constituents tend to be leached from the soil, and
carried deeper within groundwater, ultimately being covered with a layer of unimpacted water as these
compounds are removed entirely from the soil. Simultaneously, the TCE would likely be moving
dou ngradient. particularly in the transmissive sand zone observed from 15 to 25 ft bgs.
A supplemental groundwater investigation was performed in September-October 2017 with the goal to
document current groundwater concentrations and to support modeling to characterize the potential for
migration of TCE. No down gradient migration of TCE was observed, although some 2017
concentrations differed from concentrations observed when the wells were last sampled in late 2012.
The objectives for this supplemental investigation were to document trends in the concentration of TCE
and its daughter products, obtain geoehemieal data to characterize the potential for natural attenuation,
and measure hydraulic conductivity. At present there is not sufficient data to fully characterize plume
stability, characterize potential for migration, or determine if the plume is undergoing natural
attenuation. The presence of cis-1.2-dichloroethene (DCE) indicates there is some natural attenuation
occurring. Multiple rounds of groundwater monitoring show that natural attenuation of TCE is
inconsequential. "Hie highest ratio of eis-1.2-DCE to TCE concentrations is 0.09 1 (MW-15D result
from 2017). There are certainly inadequate data to conclude that natural attenuation is effectively
reducing groundwater contaminant concentrations. There is evidence indicating that natural attenuation
as remedial action would be ineffective at reducing contaminant concentrations. Other YOCs detected in
groundwater above NC 2L standards include: 1.2-diehloro benzene. 1.4-dichlorobenzene. and vinyl
chloride.
Very shallow aquifers are typically influenced by atmospheric exchange and maintain a highly aerobic
and highly oxidative condition. MW-1 demonstrates this w ith an oxidative ORP. lack of dissolved iron,
high sulfate, and nitrate in the system. MW-1 and MW1-1) highlight the lack of natural TOC. which
would be expected in the given lithology. The pH is sub-optimal for ubiquitous dechlorinators that can
perform complete dechlorination; research since the 1998 EPA protocol has advanced this
understanding. Wells within the TCE plume demonstrates some signs of acid generation (HCL is
formed w hen CI is cleaved off chlorinated solvents and is a strong acid that can acidify aquifers until
about pH 5 when microbial activity tends to halt in-situ due to methanogens pH preferences) which may
have been from historic co-contaminants such as S YOCs which could act as an electron donor in the
system. Dow ngradient of the plume, the only geoehemieal parameter which is maintaining a non-
nominal redox condition, as established in the background, is nitrate. On the redox ladder nitrate is a
poor state for dechlorination, a system must undergo sulfate reduction, iron and manganese reduction.
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and then enter methanogenesis before reaching redox states feasible for dechlorination. Surprising
amounts of methane are demonstrated in the deep wells given the ORP and other geoehemieal
parameters. The saturation point for methane at normal temperatures (20-25C) is approximately 20
nig L, Under unconfined conditions a buildup of methane a depth would bubble up to the surface. This
may be indicative of some buried organic material not identified in the site CSM. This material maybe a
non-soluble form of organic carbon otherwise more TOC would be in the groundw ater. Also of note is
that the hydrogen levels remain virtually constant. Hydrogen is the only form of electron donor the
species of dechlorinating bacteria that converts chlorinated solvent to its non-toxic end product, ethene.
Groundwater samples collected from monitoring wells has identified the presence of metals in
groundw ater at the Site. Concentrations of arsenic, cobalt, iron, manganese, and vanadium w ere
detected in groundwater above NC 2L standards or interim maximum allowable concentrations (IMACs:
Arsenic max level was 286 milligrams per liter [nig L]), These include wells in the central area of the
site near the TCE plume, and wells in the landfill area. In particular, the concentrations of arsenic
grossly exceeded groundwater standards in monitoring wells near the landfill. At present there is not
sufficient data to fully characterize the arsenic in groundwater or characterize the potential for
migration.
Pesticides were detected in groundwater samples collected from one monitoring well (MWQ2) north of
the TCE plume, with concentrations of chlordane (2.4 ug L) and dieldrin (0.011 ug L) above NC 2L
standards.
5.5 AREA OF CONTAMINATION PROPOSED FOR INTERIM ACTION
The Interim Action addresses the most elevated contaminant concentrations in soils on the Site and the
TCE contaminant mass within the groundwater plume associated with the Site. These areas of
contamination are summarized in this section.
5.5.1 Surface Soil
The aggregate ecological risk to upper trophic level receptors is driven by the concentration of metals.
4.4'-DDT. PCBs. and IIMW PAHs in surface soil at two isolated locations. BII-18 and 1511-26. as
shown in Figure 4-1. The areas of surface soil impacted are each estimated to be approximately 20 by
20 ft. w ith a depth of 1 ft. The estimated total volume of impacted soil for both locations is 800 cubic ft.
Soil results for the hot spot areas that will be removed are presented in Table 5-2a and Table 5-2b.
5.5.2 TCE in Groundwater
Site monitoring wells are shown in Figure 5-5, Monitoring well construction information is presented
in Table 5-3; a historical summary of groundw ater elevations is presented in Table 5-4. Groundw ater
data collected at the Site was screened against EPA Regional Screening Levels for Tapwater. and NC 2L
standards and IMACs. and is presented in Table 5-5a and Table 5 5b.
Data from the 2017 supplemental groundwater investigation indicate that the extent of TCE has not
changed since sampling was last performed in 2012. TCE has not been detected in the monitoring well
pair MW-16 and MW-16D. The concentration of TCE has decreased at MW-15D. while it has
increased at both MW-03 and MV-03D. Overall, the mix of chlorinated YOCs is similar to previous
sampling events (OBG. 2018).
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The area exhibiting concentrations of TCE above the NC 2L standard of 3 ug L was estimated
conservatively by using the total chlorinated compound contours from the RI (Figures 5-6 through 5-8).
The estimated area is approximately 462.500 square ft with an average thickness of 20 ft.
5.6 NATURAL ATTENUATION EVALUATION
Geochemical data from 2017 and contaminant concentration data were used to evaluate the potential for
natural attenuation of the TCE plume. During the supplemental groundwater investigation conducted in
2017, groundw ater samples w ere collected from a number of monitoring w ell pairs in the vicinity of the
TCE plume (MW-01 MW-01D. MW-15 15D. MW-03 03D. and MW-16 16D) and were analyzed for
YQCs and a range of geochemical parameters. The geochemical parameters analyzed include dissolved
oxygen (DO), nitrate, iron (II). sulfate, methane, oxidation reduction potential (ORP). hydrogen ion
concentration (pH). carbon dioxide, chloride, alkalinity, total organic carbon (TOC). temperature, and
hydrogen. Microbial parameters to determine the presence of microorganisms capable of degrading
chlorinated YOCs were not analyzed. YOC results are presented in Table 5-5b. and geochemical
parameter results are presented in Table 5-6.
Natural attenuation screening for the area of TCE contamination at the Site w as performed based on the
Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA.
1998). The screening evaluated wells within the TCE plume (MW-03 03D and MW-15 15D) and wells
downgradient of the TCE plume (MW-16 16D) in comparison to upgradient wells (MW-01 MW-01D).
For the most part, natural attenuation screening scores indicate there is limited evidence of anaerobic
biodegradation in w ells (Table 5-6). This condition is further demonstrated by the amount of TCE
relative to its degradation products present in groundwater. For example, at MW-03. the 2017
groundw ater sample contained 260 ug L of TCE. 9 ug L of cis-1.2-DCE. and no vinyl chloride. At
MW-03D. the 2017 groundwater sample contained 290 jig L of TCE. 8 fig L of cis-1.2-DCE. and no
vinyl chloride. In addition. TCE measurements in MW-03 suggest an increasing concentration trend.
Although environmental conditions are not ideal for reductive dechlorination, they are not wholly
unfavorable; the pH is at an acceptable but not ideal level and DO is not very high, but slightly outside
the preferred concentration of 0.5 nig L. The ORP values are very high, but as the ES Appendix A text
notes, the 2017 measurements appear to be erroneous (OBG. 2018). The apparent limited anaerobic
biodegradation and low TOC concentrations (maximum of 5.1 mg Lat MW-16). may indicate there is a
lack of appropriate electron donor that is needed to support strong reducing conditions.
5.7 GROUNDWATER MODELING
In an effort to better understand the potential for migration of TCE. a migration evaluation was
performed as part of the FS. The objective was to assess the potential for TCE to migrate to oil-Site
Points of Exposure (POEs). specifically surface water in Pailin Creek and groundwater in the residential
area across Pailin Creek to the west. The NCDEQ Risk Tool (NCDEQ, 2017) was used for the
evaluation, as it uses a conservative approach with no degradation, to model the migration of
contaminants in groundwater. This tool is more appropriate than a biodegradation model such as
BIOCHLOR because very little biodegradation of TCE has been demonstrated at the Site. The results of
the contaminant migration modeling indicate that TCE does not represent an unacceptable risk to surface
water (modeled concentrations at Pailin Creek would be below surface water quality standards), but that
there is the potential, if groundwater flowed beneath Pailin Creek, for TCE to reach the other side of the
creek at concentrations (5.6 ug L) slightly above the NC 2L standard (3 ug L). It is apparent that the
primary reason that TCE and other constituents related to TCE have not migrated very far is due to the
very low rate of contaminant transport. In addition, groundwater flow direction is variable in the area of
TCE contamination, so there is not a simple linear movement of contamination.
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6.0 CURRENT AND POTENTIAL FUTURE LAND AND WATER USES
Pasquotank County has zoned most of the active areas of the Site for industrial use with the southern
portion of the Site (which contains the Landfill) zoned for residential use (Figure 1-2 and Figure 1-3),
Tliere is also a small area across Pail in Creek which contains the former rail spur serving the Site that is
zoned residential. Projections of future land use made by Pasquotank County are similar to the current
zoning designations, except that the area on the southern portion of the Site is expected to be rezoned as
commercial or rural agricultural.
Two municipal water systems serve residents near the Site, the Elizabeth City Water System and the
Pasquotank County Water System. Wells used by the Elizabeth City Water System and the Pasquotank
Water System obtain w ater from both the w ater table aquifer and the Yorktown upper aquifer. The
Elizabeth City Water System uses both groundw ater wells mid a surface w ater intake. The Elizabeth
City Water System wells are located approximately 9 miles upgradient of the Site, A surface water-
intake is located off Whitehurst Lane on a canal to the Pasquotank River, which is approximately 14
stream miles upstream of the Site. The Elizabeth City Water System serves approximately 15.000
persons. The Elizabeth City system does not extend beyond the southern or western boundaries of the
Site, The Elizabeth City system borders the Pasquotank County systems, and in some places, overlaps
with it.
The Pasquotank County Water System wells are located within 3 miles of the Site, with the closest wells
located approximately 2.5 miles to the northwest (upgradient) of the Site. "Hie Pasquotank County
Water System sen ices approximately 13.650 persons. The Pasquotank County System serves water to
all southern Pasquotank County, in addition to other areas of the county.
"Illere are no active production wells on Site. The closest known domestic well to the Site is the Salem
Baptist Church well, which lies across Pail in Creek, approximately 1.5 miles west of the Site.
Groundwater beneath the Site is classified as current and potential sources of drinking w ater (EPA Class
II Aquifer). In North Carolina all groundwater classifications of aquifers are potential sources of
drinking water and are expected to be remediated for beneficial reuse (Class GA or Class GSA under
15A NCAC 02L.0201). The interim action is not intended to restore all Site groundwater to beneficial
reuse. However, it is anticipated that the remedial goals should be met by bioremediation within the
treatment zone within approximately 2 years,
Pailin Creek is classified as both fresh water (Class C) and swamp water (Class SW). while New begun
Creek is classified as saline (Class SC). Direct and Site-specific evidence collected during the field
investigations indicate that Pailin Creek is tidally influenced, aid may be more accurately described as
brackish, at least during part of the year. 'Hiere are no surface w ater intakes downstream of the Site used
for drinking water purposes.
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7.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) is required as part of the RI and provides mi evaluation of the
potential threat to human health and the environment in the absence of any remedial action (RA), The
BRA provides the basis for determining if an RA is necessary and the justification for performing a
cleanup. Consistent with EPA guidance and policy, the BRA consists of a Human Health Risk
Assessment (HHRA) and an Ecological Risk Assessment (ERA).
The HHRA evaluated cancer and non-cancer risks for existing Site conditions and current land and
water uses. The HHRA also includes an evaluation of risk for reasonably anticipated future land use
scenarios.
"Hie Baseline Ecological Risk Assessment (BERA) included a quantitative evaluation of Site risks to
aquatic and terrestrial receptors for current and future use scenarios.
7.1 SUMMARY OF HUMAN HEALTH RISK ASSESSMENT
Cancer risks and non-cancer hazards were estimated for receptors under reasonable maximum exposure
(RME) and central tendency exposure (CTE) scenarios. Remedial decisions arc based on the RME.
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
The following conclusions were made based on the results of the risk characterization:
¦ No unacceptable excess cancer risks are estimated for on-Site or oil-Site human receptors from
exposure to Chemicals of Potential Concern (COPCs) in media potentially impacted by the Site
under both RME and CTE scenarios.
¦ No unacceptable non-cancer hazards are estimated for on-Site or off-Site human receptors from
exposure to COPCs in media potentially impacted by the Site under both RME and CTE scenarios.
¦ Ingestion of drinking water from the aquifer would present an unacceptable exposure.
¦ At the request of EPA mid NCDENR. a risk evaluation based on hypothetical future residents
occupying the Site was conducted. Although residential land use is not considered a reasonably
anticipated future use. the HHRA included a residential evaluation to provide a baseline, "worst-
case" exposure scenario.
"Hie following conclusions were made based on the results of the hypothetical residential evaluation:
¦ Potentially unacceptable RME and CTE excess cancer risks were estimated for both child and adult
residents, primarily associated with exposure to benzo(a)pyrene in surface soil and arsenic in
shallow groundwater.
¦ Potentially unacceptable residential child and adult RME and CTE non-cancer hazards are presented
by exposure to PCBs. metals. SYOCs, and pesticides in surface soil and. TCE, YOCs, metals, and
pesticides in shallow groundwater.
The results of the HHRA indicate that future hypothetical residential exposure to soil are unacceptable.
A complete discussion of all risks from the Site can be found in the HHRA w hich is contained in the
Administrative Record.
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7.1.1 Identification of Chemicals of Concern
The HHRA generated a list of CO PCs by comparing the maximum detected concentration of a given
constituent to a relevant screening value. Chemicals with concentrations above screening values were
identified as COPCs, The selected human health COPCs and associated concentrations in each medium
are summarized in Tables 7-la through 7-lh.
7.1.2 Exposure Assessment
Hie exposure assessment defines and evaluates, quantitatively or qualitatively, the type and magnitude
of human exposure to the COCs at or migrating from the facility. The exposure assessment is designed
to depict the physical setting of the facility and its surroundings, to identify potentially exposed
populations and applicable exposure pathways, to determine concentrations of COCs to which receptors
might be exposed, and to estimate chemical intakes under the identified exposure scenarios.
Actual or potential exposures at a facility are determined based on the most likely pathw ays of
contaminant release and transport, as well as human activity patterns. A complete exposure pathway has
three components: (1) a source of chemicals that can be released to the environment. (2) a pathway of
contaminant transport through an environmental medium, and (3) and a human receptor. These
components can be integrated and described by means of a CSM. which is an essential element of the
exposure assessment.
7.1.3 Toxicity Assessment
Toxicity assessment involves evaluating the potential for a particular chemical constituent to cause an
increase in the incidence of adverse effects in exposed individuals and quantitatively characterizing the
chemical dose and the incidence of adverse health effects in the exposed receptor. The potential
toxicological effects induced by a given dose of a chemical are classified according to two criteria: non-
cancer effects and cancer effects. Toxicity values typically employed to calculate baseline non-
carcinogenic hazards include reference doses (Ril)s) for oral mid dermal exposures mid reference
concentrations (RfC's) for inhalation exposures: oral and dermal cancer slope factors (C'SFs) and
inhalation unit risks (IURs) are typically used to estimate carcinogenic risks. Constituent-specific
toxicity values are used to calculate potential effects for these two types of effects. Following EPA
guidance on selection of human health toxicity values, the following hierarchy of toxicological data
sources was used for the HIIRA:
¦ Tier 1 - EPA's Risk Assessment Information System.
" Tier 2 - EPA's Provisional Peer Re\ jewed Toxicity Values used in EPA's Superfund Program.
" Tier 3 - Other toxicity values including EPA and non-EPA sources of toxicity information. Tier 3
values include, but are not limited to:
¦ Agency for Toxic Substances and Disease Registry Minimum Risk Levels:
¦ California EPA values, and
¦ EPA Health Effects Assessment Summary Table values.
The non-cancer toxicity v alues applied in the risk characterizations of oral dermal hazards evaluated in
the HHRA are presented in Table 7-2. Non-cancer toxicity values used to quantify outdoor air
inhalation hazards are presented in Risk Assessment Guidance for Superfund (RAGS) Table 7-3.
Cancer toxicity values applied in the risk characterizations of oral dermal exposures evaluated in this
HHRA are presented in Table 7-4. Cancer toxicity values used to quantify outdoor air inhalation cancer
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risks are presented in Table 7-5. To assess dermal exposures, the oral toxicity data were adjusted to
reflect the absorbed dose in accordance with RAGS Part E (EPA 2004) as follows:
RfDdermal = RfDoral x Gastrointestinal absorption efficiency ( ABSgi)
CSFdermal = CSForal ABSgi
The ABSGI data used for evaluating dermal exposures were obtained from Exhibit 4-1. EPA (2004),
The RfDoral and the CSForal were calculated using the above equations only for constituents with an
ABSGI of less than 50 percent,
7.1.4 Risk Oisi rasterization
For carcinogens, risks are generally expressed as the incremental probability of an individual's
developing cancer over a lifetime as a result of exposure to the carcinogen. Excess lifetime cancer risk is
calculated from the following equation:
Risk = GDI x SF
where:
risk = a unitless probability (e.g.. 2 x 10"5) of sin individual's developing cancer
CDI = chronic daily intake averaged over 70 years (mg kg-day)
SF = slope factor, expressed as (nig kg-day)"1.
For the ambient air inhalation pathway, the estimated cancer risk was calculated as the product of
the chemical specific air exposure concentration (ECair) and the respective IUR. as follows:
Cancer Riskinhaiation = ECair x IUR
These risks are probabilities that usually are expressed in scientific notation (e.g.. LxlO"6). .An excess
lifetime cancer risk of lxlO"6 indicates that an individual experiencing the reasonable maximum
exposure estimate has a 1 in 1.000.000 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 dev eloping cancer from all other causes has been estimated to be as high as one in three
and for site-related exposures the risk is 10 4 to 10"6 T1 le potential for non-carcinogenic effects is
evaluated by comparing an exposure level over a specified period (e.g.. life-time) with an RID 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). .An HQ 1 indicates that a receptor's dose of a single The Hazard Index (HI) is generated by
adding the HQs for all COCs 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. .An HI 1 indicates that, based on the sum of all HQ's from different contaminants and
exposure routes, toxic non-carcinogenic effects from all contaminants are .An HI 1 indicates that site-
related exposures may present a risk to human health.
The HQ is calculated as follows:
Non-cancer HQ = CDI RID
where:
CDI = Chronic daily intake
RID = reference dose
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CDI and RfD arc expressed in the same units and represent the same exposure period (i.e.. chronic,
subchronic. or short-term).
For inhalation risk, the HQ was estimated by calculating the ratio of the EC«ir and the respective RfC. as
follows:
HQinlialaiion = ECair RfC
Cancer risks and non-cancer hazards were estimated for receptors for both RME and CTE scenarios.
Table 7-6 summarizes the estimated risks and hazards for each receptor. Risks and hazards are
presented for each exposure medium and summed across all media. The HHRA for off-Site media
indicated that cancer risks and non-cancer hazards were w ithin acceptable limits for all receptors. The
results of the industrial vapor intrusion screening indicate that a potentially unacceptable indoor air risk
is posed if a future commercial industrial building is constructed around monitoring w ell MW-03. which
currently does not contain a building. Note the potential vapor intrusion scenario will be further
assessed as part of the final ROD. This potential risk is attributable solely to TCE in groundwater. At
the request of EPA and NCDENR. an evaluation of hypothetical future child and adult residents was
conducted to provide a baseline "w orst-case" exposure scenario. Table 7-7 summarizes the risks and
hazards for hypothetical future residential receptors. Under a hypothetic future scenario under RME and
CTE, total hazards and cancer risks were determined to be unacceptable for both child and adult
residents. Unacceptable cancer risk estimates are driven primarily by the following:
¦ Benzo(a)pyrene in surface soil: and
¦ Arsenic in shallow groundwater.
Unacceptable non-cancer hazards are driven primarily by the following:
¦ PCBs in surface soil;
¦ Arsenic in shallow groundwater; and
¦ TCE in shallow groundwater.
Based on the results of the hypothetical resident evaluation, institutional controls (ICs) would be
required to restrict future residential use of the Site, including potable groundwater use.
7.1.5 Uncertainties
Tli is section presents a summary of the major uncertainties inherent in the risk assessment and includes a
brief discussion of how they may affect the risk estimates and conclusions.
The calculations presented in the HHRA are meant to assist the EPA remedial project manager witli
information on which to base risk management decisions. A combination of site-specific exposure
information, standard default assumptions, use of maximum and upper confidence limit concentrations,
and professional judgment were used to develop exposure assumptions for the various receptor scenarios
evaluated in the HHRA. These exposure assumptions are conservative and are likely to overestimate
hazards and risks.
The default soil incidental ingestion rate for future construction workers of 330 milligrams per day
(mg day) cited in Exhibit 1-2 of EPA's 2002 Supplemental Guidance for Developing Soil Screening
Levels for Supeifund Sites was applied for the construction worker in this HHRA. However, this value
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may overestimate potential soil exposures for these receptors. Other assessments have indicated that
incidental ingestion rates in the range of 100 to 200 mg day are appropriate for high-end soil contact
activities. Thus, the soil ingestion rate applied in the I1I1RA for future construction workers likely
results in an overestimation of risk.
For the inhalation pathway, particulate-phase and vapor-phase emissions factors were calculated.
Because the calculation of the particulate emission factor and volatilization factor includes a variety of
factors including temperature, wind speed, vegetative cover, etc.. there is uncertainty associated with the
derivation of ambient air concentrations.
Risks associated with the vapor intrusion pathway to potential future residents were based on modeled
concentrations from the groundwater data. These models use conservative model input assumptions
which often result in overestimates of risk.
The application of uncertainty and modifying factors to the data of toxieological studies used to form the
basis of the development of the toxicity factors provides another level of protect iveness to safeguard
human health. Uncertainty in risk characterization was associated with exposure to multiple chemicals
and the cumulative uncertainty from combining conservative assumptions made in earlier steps of the
risk assessment process.
7.2 SUMMARY OF ECOLOGICAL RISK ASSESSMENT
The BERA evaluated the potential for adverse effects to ecological receptors from exposure to
contaminants on or associated with the Site. The following receptor groups and exposure pathways
were evaluated in the BERA:
¦ Benthie Invertebrates. Amphibians and Aquatic Plants - Direct contact with sediment, surface water,
and pore water. Risk to these receptors was evaluated through comparison of sediment, surface
water and pore water contaminant concentrations w ith sediment and surface water screening
benchmarks,
¦ Fish - Direct contact w ith surface w ater, and ingestion of prey items. Risk to fish w as evaluated by
comparing surface water contaminant concentrations to surface water screening benchmarks and
comparing measured fish tissue contaminant concentrations witli fish tissue screening benchmarks.
¦ Aquatic-Associated Birds and Mammals - Contact w ith sediment and ingestion of prey items. Risk
to aquatic associated birds and mammals (e.g. heron and otter) was evaluated by modeling the
contaminant doses from ingesting prey items and incidental sediment ingestion from Pail in Creek,
and comparing these doses to toxicity reference values.
¦ Terrestrial Birds and Mammals - Ingestion of soil biota and incidental ingestion of soil. Risk to
terrestrial birds and mammals was evaluated by modeling the contaminant doses from ingesting prey
items and incidental soil ingestion from the site, and comparing these doses to toxicity reference
values.
7.2,1 Identification of Chemicals of Concern
The BERA refined the initial lists of COPECs for each media that were generated in the screening level
step to focus on those constituents that may pose unacceptable risks at the Site (COCs). The selected
ecological COCs and associated concentrations in each medium are summarized in Tables 7-8a tlirough
7-8e.
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7.2.2 Exposure Assessment
The Site is located at 1268 Toxey Road approximately 5.5 miles southeast of Elizabeth City in
Pasquotank County, North Carolina. The Site comprises approximately 188 acres and is situated on the
southern portion of a small peninsula that is created by three main bodies of water: the Pasquotank River
on the east. New begun Creek on the south and Pail in Creek (a tributary of New begun Creek), borders a
portion of the Site on the west. The surrounding area is primarily agricultural, except for the adjacent
area east of the Site and the west side of Pail in Creek, which have been developed for residential use.
The facility is currently active although only a portion of the Site has been developed for industrial
commercial use. Much of the Site is unpaved and largely undisturbed. The undisturbed areas comprise
habitat suitable for ecological receptors.
Terrestrial vegetative cover at the Site included herbaceous fields (e.g. grasses, blackberry (Rubus spp.).
ragweed (Ambrosia artemisifolia). and goldenrod (Solidago spp.)). shrub thickets (e.g. Chinese privet
(.Li gust rum simn.se)). and wooded areas to the south and west containing young trees (e.g. red maple
(Acer rubrum). sweet gum (Liquidambar styraciflua), loblolly pine (Firms taeda), tulip poplar
(Liriodendron tulipifera). and persimmon (Diospyros virginiana)).
Aquatic cover types included large bald cypress (Taxodium distichum) trees, with scattered swamp
tupelo (Nyssa biflora) in Cypress Swamp located near the Pailin Creek and Newbegun Creek at the Site.
Tidal Brackish Open Water adjacent to Pailin Creek and Newbegun Creek also had bald cypress trees.
Coastal Plain Small Stream Swamp in the headw aters of Pailin Creek included bald ex press, sw amp
tupelo, sweetgum. red maple, mid laurel oak (Quercus kmrifolia). Shrubs likely include giant cane
(Arundinaria gigantean ssp. tecta) and sweetbay (Magnolia virginiana).
The following federal listed species were identified as potentially present in Pasquotank County from
the U.S. Fish & Wildlife Service website;
¦ Shortnose sturgeon (Acipenser brevirostrum)
" Atlantic sturgeon (Acipenser oxyrincluis oxyrinchus)
¦ West Indian manatee (Trichechus manatus)
¦ Bald eagle (Haliaeetus leucocephalus)
¦ .American eel (Anguilla rostrata)
¦ Grassleaf arrowhead (Sagittaria weatherbiana)
"Hie federally protected Bald Eagle was observed at the Site during the field effort. However, sensitive
habitats have not been observed on or near the Site during Site activities. Fish and wildlife observed at
the site included the following:
Fish
American Eel (Anguilla rostrate), Atlantic menhaden (Brevoortia tyrannus). blue gill (Lepomis
macrochirus), bowfin (Amia calva), channel catfish (Ictalurus punctatus), gizzard shad (Dorosoma
cepedianum), golden shiner (Notemigonous crysoleucas), largemouth bass (Microptents satmoides),
pumpkin seed (Lepomis gibbosus). silver sea trout (Cynoscion nothus). spot croaker (Leiostomus
xant hunts). spotted bass (;\ ficropterus punctulatus). striped mullet (Magi! cephalus), white perch
(Morone Americana), yellow bullhead (Ameiurus natal is), and yellow perch (Perca flavescem).
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Birds
Bald eagle (Haliaeetm leucocephalus). belted kingfisher (Megaceryle alcyon). double-crested
cormorant (Phalacrocorax auritis). great blue heron (Ardea he rodi as), pied-billed grebe (Podiiymbus
podiceps). hawk (Buteo sp.). turkey vulture (Cathartes aura), and wood duck (Aix spoma).
Invertebrates
Blue Crab (CaiUnectes sapidus) and Unknown Clam (Unknown).
Mammals
Unknown Bat (Unknown). Gray Squirrel (Sciurus carolinensis). Meadow Vole (.Microtus
pennsylvanicus). and White-tailed Deer (Qdocoileus virginianus).
Herpetofauna
Eastern Box Turtle (Terrapene Carolina Carolina), Copperhead (Agkistrodon contortrix).
And Timber Rattlesnake (Crotahis horridus).
Pathw ays of exposure at the site for ecological receptors include the terrestrial (surface soils), aquatic
(surface water mid sediment), and groundw ater pathw ay (discharge to Pailin Creek and New begun
Creek). These exposure pathways for receptors associated with each media of concern are explained
further below.
The terrestrial exposure areas include the transitional habitat area, coal storage area, and WW'l'P area.
Receptors associated with these terrestrial portions of the Site may be exposed to COCs via direct
contact, incidental ingestion, and ingestion of affected food items. The inhalation of VOCs or fugitive
dust was not included in the wildlife exposure models at this pathway is generally considered
incomplete or de minimis for ecological receptors in comparison to the ingestion pathways. Receptors
for the terrestrial exposure pathway include plants, soil invertebrates, small mammals and birds. Upper
trophic level terrestrial receptors evaluated via food chain modeling in this BERA include;
¦ Southern short-tailed shrew (Blarina caroiinemia): insectivorous mammal
¦ Raccoon (Procyon lotor): omnivorous mammal
¦ Red-tailed hawk (Buteo jamaicensis): predatory bird
¦ .American robin (Turdm migratorius): invertivorous bird
Pailin Creek provides an aquatic exposure pathway for aquatic invertebrates and fish that are potentially
exposed via direct contact, incidental ingestion, and the aquatic food chain to Site-related COCs in
surface water and sediment. Some COCs have the potential to bioaccomulate in both fish and
invertebrates, mid therefore there is a potential for upper trophic level aquatic receptors to be exposed to
COCs through ingestion of these organisms.
Groundwater How patterns at the Site indicate that groundwater COCs may be transported to surface
w ater bodies (Pailin Creek and New begun Creek). Therefore, aquatic receptors, including upper trophic
level receptors may become exposed to groundwater COCs via direct contact, incidental ingestion, and
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ingestion of affected prey species. In addition, groundwater discharge to sediment pore water may
expose aquatic organisms (e.g. benthos, fish) in creek sediments to Site COCs.
Upper trophic level aquatic receptors evaluated via food chain modeling in the BERA include:
" River otter (Lonfra canadensis): semi-piscivorous mammal
¦ Great blue heron (Ardea herodias): piscivorous bird
¦ Green heron {But or ides virescem): piscivorous bird
Exposure point concentrations (EPCs) were calculated for all constituents that were retained in the
BERA screening process. Statistical and procedural methods were applied to the data in order to
develop the media-specific EPCs for constituents of potential ecological concern as follows: where a
given data set contained less than three sample points or only one unique detected sample, the maximum
detected concentration for each chemical in that data set was used as the EPC: for sets with four or more
data points and at least two unique detected samples, statistical methods were applied. ProUCL
statistical software package (Version 5.0; EPA, 2013c) was used to examine the data distribution and
develop an Upper Confidence Limit (UCL) of the mean (usually 95% UCL), ProUCL was run using
Regression on Order Statistics, to account for noil-detect samples in the data set. The UCL
recommended by ProUCL software was selected as the EPC except in instances where multiple UCLs
were recommended, in which case the first recommended UCL was selected and utilized in the BERA.
This methodology was adopted to standardize the selection of UCLs in situations where ProUCL
provided more than one option. The maximum detected concentration was used as the EPC if it was
exceeded by the recommended UCL. Exposure area-specific EPCs are presented in Tables 7-9 through
Table 7-11
Soil EPCs for constituents were used to estimate risk for terrestrial upper trophic level receptors using tin
uptake factor modeling approach to estimate tissue concentrations for plant forage and small (prey)
mammals. Measured concentrations of constituents in terrestrial invertebrate tissue were used to
determine food borne exposure to invertivorous wildlife through food chain modeling. Fish tissue was
collected on a fillet and remains basis. Hie former allowed for an evaluation of risk associated with the
portion of the fish typically consumed by humans while the reconstituted whole-body tissue
concentration (fillet plus remains) was used to represents the whole-body tissue concentration available
to piscivorous receptors. Benthic invertebrate tissue (whole-body) was also collected for chemical
analysis. "Hie calculation of ecological risk to aquatic upper trophic level receptors was conducted by
incorporating measured fish and aquatic invertebrate tissue concentrations in the wildlife food chains
models.
7.2,3 Ecological Effects Assessment
The study design was developed to evaluate the assessment endpoints and address the measurement
endpoints outlined in the BERA to fulfill the project quality objectives using a multiple lines of evidence
approach. The general assessment endpoints for the site are listed below:
¦ The health (i.e.. reproductive success, growth, mid or survival) of invertivorous and predatory bird
populations likely to forage on prey available from terrestrial portions of the Site.
¦ The health (i.e.. reproductive success, growth, and or survival) of invertivorous and omnivorous
mammal populations inhabiting the Site.
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" Toxic effects to the Pailin Creek aquatic invertebrate community via direct contact with Site
sediments.
¦ Toxic effects to aquatic organisms and wildlife via direct contact with Site surface waters,
¦ The health (i.e.. reproductive success, growth, mid or survival) of the Pail in Creek fish community.
¦ The health (i.e., reproductive success, growth, mid or survival) of piscivorous bird and piscivorous
mammal populations foraging in Pailin Creek.
The measurement endpoints for the terrestrial and aquatic exposure areas are described briefly below
and a summary of the assessment endpoints and measurement endpoints for this study area is provided
in Table 7 16
Terrestrial Exposure .Area.
¦ To assess viability and function of the invertivorous bird community, the following measurement
endpoints were selected:
1. Comparison of the modeled dietary doses, based on Site surface soil and surface water COC
concentrations and site invertebrate tissue COC concentrations, to toxicity reference value
(TRYs) for the .American robin.
2. Comparison of soil COC EPCs to Eco-SSL values for birds.
¦ To assess viability and function of the predatory bird community, the following measurement
endpoints were selected:
1. Comparison of dietary doses, based on surface water, surface soil, and modeled small
mammal tissue EPCs. to TRYs for the red-tailed hawk.
2. Comparison of soil EPCs of COCs to Eco-SSL values for birds.
¦ To assess viability and function of the viability and function of the invertivorous mammal
community, the following measurement endpoints were selected:
1. Comparison of modeled dietary doses, based on Site surface soil and surface water EPCs of
COCs and site invertebrate tissue COC concentrations, to TRYs for the southern short-tailed
shrew.
2. Comparison of soil EPCs of COCs to Eco-SSL values for mammals.
¦ To assess viability and function of the omnivorous mammal community, the following measurement
endpoints were selected:
1. Comparison of the dietary doses, based on Site surface soil mid surface water EPCs and site
invertebrate tissue COC concentrations, and modeled plant and small mammal tissue COC
concentrations, to TRYs for the raccoon.
2. Comparison of soil EPCs of COCs to Eco-SSL values for mammals.
Aquatic Exposure .Area
¦ To assess viability and function of the aquatic invertebrate community, the following measurement
endpoints were selected:
f. Comparison of exposure point sediment concentrations of COCs in Pailin Creek to state and
federal sediment criteria and guidance values (Region 4 Waste Management Division
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Screening Values for Hazardous Waste Sites [chronic], [EPA. 2001]; ECO Update:
EeoTOX Thresholds [EPA. 1996]).
2. Comparison of EPCs of COCs in Pailin Creek crab tissue to tissue COC criteria for the
protection of aquatic invertebrates,
" To assess viability and function of the aquatic organism community, the following measurement
endpoints were selected:
1. Comparison of EPCs of Pailin Creek and Site shallow groundwater COCs to state and
federal surface water criteria and guidance from:
» Region 4 Waste Management Division Screening Values for Hazardous Waste Sites
(chronic; EPA. 2001)
» Region 3 Biological Technical Assistance Group (BTAG) Marine Screening
Benchmarks (EPA. 2013a)
» NCDENR Saltwater Aquatic Life Standards (NCDENR, 2013)
» National Recommended Water Quality Criteria (EPA. 2013b)
» EPA EcoTOX Screening Criteria Ambient Water Quality Criteria (AWCQ) Tier II
Values (EPA. 1996),
¦ To assess viability and function of the fish community, the following measurement endpoints w ere
selected:
1. Comparison of exposure point surface water COC concentrations to state and federal surface
water criteria and guidance values for the protection offish from Region 4 Waste
Management Division Screening Values for Hazardous Waste Sites (chronic) (EPA. 2001).
Region 3 BTAG Marine Screening Benchmarks (EPA. 2013a). NCDENR Saltwater Aquatic
Life Standards (NCDENR. 2013). National Recommended Water Quality Criteria (EPA.
2013b). EPA EeoTOX Screening Criteria AWCQ Tier II Values (EPA. 1996).
2. Comparison of EPC of COCs in fish tissue to applicable tissue TRVs from literature.
¦ To assess viability and function of the piscivorous bird community, the follow ing measurement
endpoints were selected:
1. Comparison of dietary doses of COCs based on EPCs in Pailin Creek sediment, surface
water, and measured prey (i.e.. crab, finfish) COC tissue concentrations to TRVs for the
green heron and great blue heron.
¦ To assess viability and function of the semi-piscivorous Mammal community, the following
measurement endpoints were selected:
1. Comparison of dietary doses of COCs. based on EPCs in Pailin Creek sediment, surface
water, and measured prey tissue concentrations, to TRVs for the river otter,
7.2.4 Ecological Risk Characterization
Risk characterization was completed for the selected COCs by computing the ratio of EPC to screening
benchmarks for lower organism categories and computing the ratio of the estimated receptor COC dose
(total daily intake) to TRVs for upper trophic level organisms (mammals and birds). Two TRVs are
utilized for each receptor, a no-observed adverse effects level (NOAEL) TRV and a lowest observed
adverse effects level (LOAEL) TRV. NOAEL TRVs are the most conservative with LOAEL TRVs
being less conservative. Potential ecological impacts are presented in the form of an HQ that compares
media-specific EPCs for COCs or modeled doses of COCs to upper trophic level receptors to established
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effects levels or doses for those COCs. The HQs for the community level assessment are derived by
dividing the media-specific EPCs by the criteria selected for that compound. The HQs for upper trophic
level receptors are derived by dividing the receptor total dietary intake by the selected TRY for that
compound. Results of the risk characterization are further discussed below based on the exposure area.
Terrestrial Exposure Area:
¦ Food chain modeling identified copper, lead, selenium and HMW PAHs as drivers of potential risk
estimates for the American robin, with other inorganics and PCBs as lesser contributors to risk.
¦ Food chain modeling does not suggest the potential for adverse effects to the red-tailed hawk.
¦ Food chain modeling identified arsenic, barium, cadmium, copper. lead, selenium, zinc, and HMW
PAHs as potential risk drivers for the short-tailed shrew. Risks to the short-tailed shrew are driven
primarily by measured constituent concentrations in prey tissue and incidental ingestion of soil.
¦ For raccoons, food chain modeling identified arsenic and HMW PAHs above a NOAEL-based risk
threshold of one. but only marginally so (1.1 and 4.7. respectively). Corresponding LOAEL-based
HQs are below one for all constituents. Given the marginal exeeedance and variability, and
uncertainty associated with food chain modeling, the raccoon is not likely at risk from constituents in
Site surface soil.
¦ Taken holistieally. the potential for unacceptable ecological risk exists due exposure to surface soil
and prey tissue COCs in localized areas of the Site.
Aquatic Exposure .Area:
¦ HQ ratios developed for evaluation of the aquatic invertebrate community suggest the potential for
adverse effects, how ever examination of COCs in aquatic invertebrate tissue indicate only three
organic compounds were detected, compared to the 25 COCs retained for evaluation in Pailin Creek
sediment. It is more likely that the COCs detected in tissue are associated w ith regional ambient
conditions (for example, agricultural runoff) and that site related COCs in sediment do not pose
unacceptable risk to the aquatic invertebrate community.
¦ HQ developed for evaluation of the aquatic organism community suggest the potential for adverse
effects, from copper, barium, iron and manganese in surface water, however the concentrations
detected only marginally exceed conservative screening values. Examination of COCs in
groundw ater also suggests the potential for adverse effects from mostly metals; how ever, this direct
comparison does not account for dilution of ground'water at the surface water discharge interface.
Taken collectively. COCs in Pailin Creek surface water adjacent to the Site are unlikely to adversely
affect the community of w ater-column biota.
¦ HQ ratios developed for evaluation of the fish community do not suggest the potential for adverse
effects.
¦ Food chain modeling does not suggest the potential for adverse effects to the great blue heron or the
river otter. The potential for unacceptable risk to the green heron was identified for copper, zinc,
and HMW PAHs. However. NOAEL-based HQs were only marginally above one (range 1.1-3.2).
and LOAEL-based HQs w ere less than one for these constituents, w ith the exception of copper
which was 1.1. Therefore, green herons associated with the Pailin Creek are not thought to be at
unacceptable risk from site related contaminants.
¦ Taken holistieally. unacceptable ecological risk associated with exposure to the surface water or
sediment of Pailin Creek is believed to be unlikely.
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The results of the BERA indicate that although some screening criteria were exceeded in the
community-level analysis, measured site related contamination does not appeal* to pose unacceptable
risk to aquatic ecological receptors. Therefore, no RA is proposed for the aquatic exposure area. For
terrestrial exposure pathways, both community-level HQs and HQs estimated for certain upper trophic
level receptors exceed one for some constituents. Therefore, potential exists for unacceptable ecological
risk based on the EPCs of some constituents that were detected in surface soil. The elevated EPC's and
resulting risk estimates were driven primarily by discrete locations where constituents were found in
surface soil and prey item tissue at concentrations that were elevated relative to most other areas of the
Site. The Remedial Action Objective (RAO) for this exposure scenario is to mitigate unacceptable
ecological risk estimated for the affected terrestrial receptors, primarily by remediating localized areas
of impacted surface soil.
7.2,5 Uncertainty
Uncertainty is inherent in each step of the ERA process because each parameter used in estimating risk
has a degree of variability and uncertainty associated with it. Beginning with the data collection and
analysis and continuing through the risk characterization, reasonably conservative assumptions are made
for main of the parameters used in the BERA to try to minimize the chance of underestimating risk to
ecological receptors. This section summarizes the major factors contributing to the uncertainty
associated with the BERA in an effort to minimize their effects on the interpretation of results. The
main sources of uncertainty discussed in this section are;
¦ Uncertainty associated with site characterization, data quality and derived constituents -
Uncertainty related to site characterization may arise due to the number of samples used to
characterize a given area and or whether potential areas of elevated concentrations have been
sampled. In addition, if samples were collected more than 5-10 years ago. questions related to the
continued relevance of the data due to either the age of the sample, or changes in Site conditions
since the samples were collected may also contribute to uncertainty. Data quality can impact the
reliability of results and conclusions of ERAs. To reduce the amount of uncertainty introduced into
the quantitative assessment, only data with known and conventional standard qualifiers were
selected for evaluation. Uncertainty is also associated with the derivation of constituent
concentrations from speciated PCBs (Aroelors). ehlordane. and grouping of low molecular weight
(LMW) HMW PAHs. The quality of the data concerning speciation of these constituents can affect
the uncertainty surrounding the BERA results and conclusions relative to total PCBs. Individual
PAH compounds were evaluated as two groups (LMW HMW PAHs). developed based on their
molecular weight, which has been found to correlate with toxicity. Grouping individual PAHs
contains some uncertainty, including the use of surrogate screening and TRYs (LMW Avian TRY).
It should also be noted that the 2011 tissue sampling effort was conducted with the dual purpose of
providing analytical data to support both the HHRA and the BERA. hi the BERA. the results from
both the fillet and remains portions were mathematically combined to represent concentration in an
entire forage fish. There is a small amount of uncertainty associated with reconstituting a whole-
body concentration relative to a true w hole-body tissue sample. Uncertainty could influence
estimated HQs in either direction.
¦ Uncertainty associated with selection of evaluated media - Uncertainty related to media can be
introduced by including or excluding media that is not ecologically relevant, such as soil below the
biologically active soil horizon (A-horizon. typically 0 to 12 inches bgs). To reduce and minimize
uncertainty in the BERA. only ecologically relevant media were evaluated, historical samples of
dynamic media were excluded, and only ecologically relevant areas of the Site were assessed.
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" Uncertainty associated with selection of t.'OCs - Maximum detected concentrations of
constituents in surface soil, surface water, surface sediment, and shallow groundwater were
compared to criteria for the protection of ecological receptors. For each given medium, the lowest of
the selected criteria w as chosen for this comparison. Given that the screening values may vary over
orders of magnitude for the same compound, selecting the lowest screening values may introduce a
conservative bias. Detected constituents that did not have established screening values were carried
forward for further evaluation in the risk assessment. In addition, detected compounds that are
considered bioaccumulative w ere retained as COCs even if their maximum detected concentration
did not exceed their respective screening criterion and their frequency of detection was
approximately 6°o. The use of surrogate compounds for screening criteria also introduces
uncertainty into the screening process.
¦ Uncertainty associated with habitat suitability - The quality and quantity of habitat varies
significantly across the Site and portions of the Site may offer more or less suitable habitat for the
receptors selected for this assessment. Site receptors will likely spend more time in areas with
preferred habitat and therefore exposures in these areas will be greater than exposures in poorer
habitat; how ever, habitat quality itself within the Terrestrial or Aquatic Exposure Areas was not
considered in this assessment. As such, inclusion of some portions of the Site containing marginal
or low-quality habitat for evaluation in the BERA may result in an overestimation of ecological
risks.
¦ Uncertainty associated with calculation of exposure point concentrations - Uncertainties
associated w ith the development of EPCs are typically related to the quality and quantity of the data
available and the protocols used to generate the EPC. The methodology used to develop the EPCs
used in this BERA is discussed in detail in Section 7.2.2. Where a given data set contained less than
three sample points or only one unique detected sample, the maximum value for each analyte in that
data set was used as the EPC.
¦ Uncertainty associated with the exposure and toxicity - "Hiere is uncertainty associated with each
measured variable used in the ecological receptor exposure models used in the BERA. Literature
derived parameters for each receptor's exposure values introduces uncertainty. Parameters such as
body w eight, food ingestion rate, media ingestion rate, or the percentage of dietary components in a
receptor's diet have significant impacts on the resulting risk calculations. The use of these literature
derived values in lieu of site-specific data regarding receptor biometrics, prey percentages, land use.
or physiology imparts conservative uncertainty to the risk estimates. In addition, toxicity values are
available for only a limited number of species. 'Hie majority of mammalian TRYs used in this
assessment have been derived from studies that used rats or mice as experimental animals. These
TRYs were not adjusted for body size differences between the experimental animal and the receptors
evaluated herein (no allometric adjustments). The direct application of unadjusted TRYs (for
example, mouse to red fox) does not account for physiological differences betw een species and may
lead to an overestimation or underestimation of risk. For COCs without TRYs. risks to ecological
receptors could not be estimated, resulting in a potential underestimation of risks. In the absence of
certain literature values, an extrapolation may be made from one toxicity value to another (e.g..
sum)gate use for uptake factors). In some cases, it was necessary to extrapolate LOAELs to
NOAELs using an uncertainty factor of 10. This extrapolation can also lead to uncertainty in risk
estimates; however, the general direction of bias is not known.
7.2.6 Conclusions of Ecological Risk Assessment
The BERA evaluated risks to receptors under current use scenarios. A BERA quantifies risk to different
potentially exposed ecological receptors a.s an HQ. If an HQ is calculated to be equal to or less than 1.
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then no adverse effects are expected because of exposure. If the HQ is greater than 1. adverse effects
are possible.
Unacceptable ecological risk to aquatic organisms, birds and mammals associated with exposure to
surface water, sediment or biota of Palin Creek is unlikely. However, residual concentrations of COCs
(PCBs. PAHs. metals) in soil at localized areas on the Site potentially pose unacceptable risks to
terrestrial wildlife (songbirds and small mammals).
7.3 BASIS FOR ACTION
Based on the results of the RI and the risk assessments, EPA has determined that the Selected Remedy
presented in this IROD. is necessary to protect public health or welfare and the environment from actual
or threatened releases of hazardous substances into the environment.
Figure 4-1 and Figure 4-2. respectively illustrate the location and extent of the surface soil
contamination presenting unacceptable ecological risks and groundwater contamination presenting
human health ingestion risks to be addressed by this interim action.
7.3.1 Surface Soil
The aggregate ecological risk to the upper trophic level receptors is driven by the concentration of
PCBs. HMW PAHs. 4.4'-DDT and several metals notably arsenic, cadmium, copper, lead, selenium and
zinc in the surface soil at two locations (BH-18 and BH-26), The area at each location is estimated to be
approximately 20 by 20 ft. with a depth of 1 ft (see Figure 4-1). 'Hie total estimated volume of
impacted soil for both locations is estimated to be 800 cubic ft.
7.3.2 Groundwater
The area exhibiting concentrations of TCE above the NC 2L standard of 3 jig L was estimated
conservatively by using the total chlorinated compound contours from the RI. The estimated area is
approximately 462.500 square ft with and average thickness of 20 ft (see Figure 4-2). Additionally,
concentrations of arsenic, cobalt, iron, vanadium. 1.2-dichlorobenzene. 1.4-dichlorobenzene. vinyl
chloride, total chlordane, and dieldrin were found above the NC 2L standards or NC IMACs, and are
generally located within the footprint of the TCE plume, except for metals which are also located in the
area of the landfill. This interim action is designed to address TCE only.
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8.0
REMEDIAL ACTION OBJECTIVES
The CERCLA Act of 1980. as amended by Section 121(b) of Superfund .Amendments and
Reauthorization Act (SARA) of 1986, requires the selection of RAs that attain a degree of cleanup
which ensures protection of human health and the environment, are cost effective, and use permanent
solutions and alternative treatment technologies or resource technologies to the maximum extent
practicable. To satisfy CERCLA requirements. RAOs were developed for the contaminated soils and
groundwater at the Site.
RAOs describe in general terms w hat a RA should accomplish to be protectiv e of human health and the
environment. RAOs are statements that specify the environmental media of concern, contaminant type,
potential exposure pathways to be addressed by RAs. receptors to be protected, and remediation goals or
cleanup levels (40 Code of Federal Regulations [CFR] Section 300.430[e][2][i]).
The RAOs were developed based on the current and future land use as industrial property, w ith the
objective of protecting the public from potential current and future health risks, as well as to protect the
environment. The RAOs for the interim action are summarized below.
Surface Soil
¦ Minimize ecological exposure (i.e.. direct exposure and incidental ingestion) to COCs in soil that
pose unacceptable ecological risk.
Groundwater
¦ Minimize off-site migration of COCs in groundw ater to off-site surface w ater or potential
groundwater POEs at concentrations exceeding the Federal Safe Drinking Water Act (SDW.A)
Maximum Contaminant Levels (MCLs) and NC 2L standards (15A NCAC 02L.0201).
¦ Restore TCE levels in groundwater to the extent practicable to meet Federal SDWA MCLs and NC
2L standards throughout the treatment area of the plume, based on the classification of the aquifers
as a potential source of drinking water (Class GA or Class GSA) under 15A NCAC 02L.0201.
Remaining residuals of TCE and other contaminants that exceed MCLs or NC 2L standards w ill be
addressed in the final remedy for the Site in the final ROD.
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9.0
INTERIM CLEANUP LEVELS
The aim of cleanup levels in this IROD is to meet ARARs to the extent practicable and eliminate
exposure to contaminants of concern such that human health and the environment are adequately
protected. This can be achieved by eliminating exposure pathways or reducing contaminant
concentrations to levels that are accepted to be adequately protective of human health and the
environment. The cleanup levels for the interim groundwater response action are presented in the table
below:
Interim Cleanup Levels for Chemicals of Concern in Groundwater
||V0Cs
Hg/L
Source
Trichloroethylene
3
NC 2L
The NC 2L cleanup level, or ARAR, for TCE is 3 ug/L. The Interim action aims to restore TCE levels in
groundwater to the extent practicable to meet the cleanup level. The remaining residuals of TCE and
other contaminants that exceed MCLs or NC 2L standards will be addressed in the final remedy for the
Site in the final ROD.
PRGs for the interim ecological soil response action have not been developed. The horizontal and
lateral extents of the soil contamination illustrated on Figure 4-1 are based on the aggregate ecological
risk to upper trophic level receptors is driven by the concentration of metals, 4,4'-DDT, PCBs, and high
molecular weight PAHs in surface soil at two isolated locations. Ecological-risk based soil cleanup
levels will be documented in the final ROD for the Site.
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10.0 DESCRIPTION OF ALTERNATIVES
The April 2018 Proposed Plan screened the following remediation alternatives:
For Surface Soil;
Alternative 1
Alternativ e 2
For Groundwater:
Alternative 1
Alternative 2
Alternativ e 3
No Action
Excavation and OtY-Site Disposal
No Action
ICs
Enhanced Bioremediation and ICs
Institutional controls (ICs)
The NCP states that ICs, while not actively cleaning up the contamination at the site, can control
exposure, and therefore, are considered to be limited action alternatives. The NCP preamble states:
"institutional controls will usually be used as supplementary protective measures during implementation
of groundwater remedies." The objectives for the ICs are to prevent human exposure to contaminants
above levels that pose unacceptable risk in either the soil or groundwater and not allow use of Site
related contaminated groundwater for potable purposes. ICs can also be used to maintain the integrity of
the any existing or future monitoring or remediation system. NCDEQ will take responsibility to
maintain, monitor, and enforce the ICs according to the IROD.
"Hie following generally describes those ICs to be considered for implementation at the Site:
¦ file Triangle Pacific property would be for industrial commercial uses only.
¦ A restriction to prohibit installation of a groundwater production well at the Site or to prohibit the
use of the groundwater as a source for drinking water without appropriate treatment would control
exposure to groundwater.
Should any IC remedy tail. EPA and NCDEQ will ensure that appropriate actions are taken to
reestablish the remedy's proteetiveness and may initiate legal action to either compel action by a third
party mid or to recov er costs for remedying any discovered IC violations.
Below is a summary and brief description of the remedial alternatives that were evaluated in detail in the
2018 FS and April 2018 Proposed Plan. These remediation alternatives were evaluated from a technical,
environmental, and cost-effectiveness perspective. Also provided for each alternative (where possible)
is the construction time-frame, capital, annual operation & maintenance (O&M). total present worth
costs, and estimated time-frame for the alternative to achieve the clean-up levels. Where applicable, the
total present worth cost was developed using a duration of 30 years (for those applicable activities at a
discount rate of 7°o). The disposal or placement of any excavated material will meet any land disposal
restrictions.
10.1 DESCRIPTION OF REMEDY COMPONENTS
The FS Proposed Plan evaluated two different soil remediation alternatives.
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10.1.1 Remedial Alternatives for Surface Soil
I 0.1. 1.1 Alternative I: No Action
Hie No Action alternative maintains the Site as is. The NCP requires that a "No Action" alternative be
developed as a baseline for comparing other remedial alternatives. No active cleanup activities will be
initiated. This alternative provides for an assessment of the environmental conditions if no R As are
implemented. There would be no capital or O&M costs associated with the No Action alternative.
10,1.1.2 Alternative 2: Excavation and Off-Site Disposal
Alternative 2 consists of "hot spot" removal or excavation of surface soil (up to 1 ft bgs) at two locations,
where concentrations of COCs drive ecological risk for the Site; off-site disposal at a RCRA Subtitle D
(solid waste). RCRA a Subtitle C (hazardous waste) or a TSCA landfill. Confirmation samples will be
collected and the open excavation areas w ill be backfilled with clean fill. It's will be implemented by
the state to prohibit residential use and redevelopment of the areas addressed by this interim action. The
proposed excavation area is depicted on Figure 4-1. Hie quantity of soils to be excavated for this
alternative is estimated to be 20 by 20 ft. with a depth of 1 ft. "Hie total estimated total volume of
impacted soil for both locations is estimated to be 800 cubic ft.
Estimated costs for Alternative 2 are as follows:
¦ Capital Cost: $ 151.050
¦ 30-Year net present worth (NPW) ofO&M: $ 0
¦ 30-Year NPW of Alternative S-2; $ 151.050
Alternative 2 is anticipated to be completed within one construction season. .Any remaining soils with
unacceptable ecological risks will be addressed in the final ROD.
10.1.2 Remedial Alternatives for Groundwater
Tliis section summarizes the three remedial alternatives evaluated for groundwater. Groundwater at the
property and downgradient poses a risk to human receptors because concentrations of TCE exceed
human health risk criteria. Due the size of the groundwater plume, the known area of highest
concentration immediately surrounding MW-3 is being targeted for the initial phase of remediation.
RAOs should be achieved fully with the final ROD, approximately 2-3 years after this IROD.
10.1.2.1 Alternative 1: No Action
"Hie No Action alternative allows the Site to remain in its current environmental condition. The NCP
requires that a "No Action" alternative be developed as a baseline for comparing other remedial
alternatives. No active cleanup activities will be initiated. Periodic monitoring of existing wells and
reporting will be completed every five years to con linn Site conditions. This alternative provides for an
assessment of the environmental conditions if no RAs are implemented. There would be no capital or
O&M costs associated with the No Action alternative.
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10.1.2.2 Alternative 2: Institution at Controls
Alternative 2 would consist oflCs in the form of deed restrictions that would be established for the Site,
These IC s would prevent exposure (for example, dermal contact, ingestion and inhalation) to COCs in
groundwater, A restriction to prohibit installation of a groundwater production well at the Site or to
prohibit the use of the groundwater as a source for drinking water w ithout appropriate treatment would
control exposure to groundwater. As required by CERCLA. a review of Site conditions and risks would
be conducted every 5 years because contamination would remain on site above levels that allow for
unlimited use and unrestricted exposure. There would be out-year costs associated with maintaining ICs
annual certification that the land use restrictions are being met.
Estimated costs for Alternative 2 are as follows:
¦ Capital; $70,000
¦ 30-Year NPW of O&M: $0
" 30-Year NPW of Alternative 2: $70,000
10.1.2.3 . llternative 3: Enhanced Bioremediation and Institutional Controls
Alternative 3 would consist of the injection of a liquid amendment (for example. 3D MicroemulsionS or
similar) to enhance the biodegradation of chlorinated compounds in the groundwater via reductive
dechlorination. Enhanced biodegradation would be conducted in the area surrounding monitoring well
MW-03 with the objective of accelerating degradation of TCE in groundw ater to reduce the
concentration below levels that may represent a risk for potential exposure due to ingestion of drinking
water, hi addition, enhanced biodegradation would create a biologically active area on the downgradient
edge of the TCE plume, further limiting the potential for migration to off-site surface water mid
groundwater POEs. thus facilitating groundwater restoration. Figure 4-2 depicts the proposed injection
areas.
A treatability study may be conducted during the Remedial Design phase to evaluate potential
enhancements that would be effective for treating TCE at the Site. Enhanced biodegradation will not be
immediately effective: therefore. ICs will be implemented as described in Alternative 2 until RAOs are
achieved. As required by CERCLA. a review of site conditions and risks would be conducted every five
years since contamination would remain on site above levels that allow for unlimited use and
unrestricted exposure.
Estimated costs for Alternative 3 are as follows:
¦ Capital: $904,424
¦ 30-Year NPW of O&M: $297,674
¦ 30-Year NPW of Alternative 3: $1.202.099
With this alternative, groundwater RAOs would be met immediately upon implementation of ICs. and
expected to be met by bioremediation within the treatment zone within approximately two years, and
outside the treatment zone could be achieved by natural attenuation over a longer time.
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11.0 COM PA RAT IV E ANALYSIS OF ALTERNATIVES
Section 9 described the remedial alternatives presented in the 2018 FS document April 2018 Proposed
Plan, This section summarizes the detailed evaluation of these remediation alternatives in accordance
with the nine (9) criteria specified in the NCP. 40 CFR Section 300.430(e)(9)(iii). This evaluation was
completed in accordance with the nine criteria summarized in the tables below.
Table 11-1 summarizes the comparative analysis for the soil alternatives and Table 11-2 summarizes
the comparative analysis for the groundwater alternatives,
11.1 THRESHOLD CRITERIA
In order for an alternative to be eligible for selection, it must be protective of both human health and the
environment mid comply with ARARs, However, the requirement to comply with ARARs can be
waived in accordance to 40 CFR Section 300.430(f)( 1 )(ii)(C). If an alternative tails to protect human
health or the environment, or does not comply with ARARs. then this alternative cannot be selected.
Below is a discussion of the alternatives in comparison with these two threshold criteria,
11.1.1 Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative provides
adequate protection of human health and the environment and describes how risks posed through each
exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and or
It's, This assessment considers both short-term and long-term time frames,
ILL 1.1 Surface Soil
Alternative 2, Excavation and Off-Site Disposal minimizes and potentially eliminates the ecological risk
to terrestrial wildlife (songbirds and small mammals). Under the current and expected future industrial
and commercial land use. soil does not pose an unacceptable risk to human health. However, there is
unacceptable risk to human health should land use be zoned and developed into residential properties.
Should the Site be designated as residential use in the future, that could be addressed through additional
response actions or ICs, prohibiting residential use.
EVALUATION CRITERIA FOR SI PERFUM) REMEDIAL ALTERNATIVES
Threshold Criteria
Overall Protectiveness of Human Health and the Environment determines whether an alternative
eliminates, reduces, or controls threats to public health and the environment through ICs. engineering
controls, or treatment.
Compliance with ARARs evaluates whether the alternative meets Federal and State environmental
statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified.
Evaluation Criteria
Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection
of human health and the environment over time.
Reduction of Toxicity. Mobility, or I olume of Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to
move in the environment, and the amount of contamination present.
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EVALUATION CRITERIA FOR SI PERFI NI) REMEDIAL ALTERNATIVES
Short-term Effectiveness considers the length of time needed to implement an alternative and the risks
the alternative poses to workers, residents, and the environment during implementation.
Implementability considers the technical and administrative feasibility of implementing the alternative,
including factors such as the relativ e availability of goods and services.
Cost includes estimated capital and annual operations mid maintenance costs, as well as present worth
cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost
estimates are expected to be accurate w ithin a range of+50 to -30 percent.
Modifying Criteria
State/Support Agency . Acceptance considers whether the State agrees with the EPA's analyses and
recommendations, as described in the RI FS and Proposed Plan,
Community Acceptance considers whether the local community agrees with EPA's analyses and
preferred alternativ e. Comments received on the Proposed Plan are an important indicator of
community acceptance.
Alternative 2 is protective of the environment in the short-term because it removes soil containing the
highest COC concentrations. A follow-up ecological risk assessment will be conducted at the Site, after
the interim soil response action is implemented to determine if a CERCLA response is needed to address
residual contamination.
11.1 J. 2 Groundwater
Alternatives 2 and 3 are protective of human health and the environment in the short term. Under the
current and reasonably anticipated future land use (industrial) there are no unacceptable risks associated
with exposure to groundwater because it is not used at present as a drinking water source, but potentially
could be in the future w ithout proper intuitional controls. There is unacceptable risk to future residents
from exposure to COCs in groundwater should it be used in the future and this would be addressed in
the interim through treatment and ICs.
A groundwater migration evaluation (2018 FS. Appendix B) indicates that TCE is unlikely to impact
off-site groundwater and surface water points of exposure, and therefore does not represent a potential
risk to human or ecological receptors in off-site areas,
11.1,2 Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA and NCP §300,430(f)(l)(ii)(B) require that RAs at CERCLA sites at least
attain legally applicable or relevant and appropriate Federal and State requirements, standards, criteria,
and limitations which are collectively referred to as ARARs. unless such ARARs are waived under
CERCLA section 121(d)(4).
Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under Federal environmental or State environmental of
facility citing laws that specifically address a hazardous substance, pollutant, contaminant. RA. location,
or other circumstance found in CERCLA site. Only those State standards that are identified by a state in
a timely manner mid that are more stringent than Federal requirements many be applicable. 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 of
Triangle Pacific IROD 11 -2
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facility citing laws that, while not "applicable" to a hazardous substance, pollutant, contaminant. RA.
location, or other circumstance at a CERCLA site addresses problems or situations similar to those
encountered at the CERCLA site that their use is well-suited to the particular site. Only those State
standards that are identified in a timely manner mid that are more stringent than Federal requirements
many be relevant and appropriate.
Compliance with ARARs addresses whether a remedy will meet all of the ARARs of other Federal and
State environmental statues or provides a basis for invoking a waiver.
11.1.2.1 Surface Soil
Tliere are no chemical-specific ARARs for soil. Excavation and backfilling activities under Alternative
2 would be conducted in a maimer consistent with floodplain regulations and air quality standards.
Solid and TSCA wastes would be managed in accordance with applicable state and federal handling and
disposal regulations. Transportation activities would be completed in accordance with applicable state
and federal requirements, by licensed and permitted haulers.
11.1.2.2 Groun dwater
Alternative 2 ICs would not attain chemical-specific ARARs. Alternative 3. Enhanced Bioremediation.
would achieve chemical-specific ARARs in the treatment zone over a more rapid timeframe.
Achievement of the State and Federal drinking water standards w ould be achieved in a future ROD.
Location-specific ARARs are not triggered by Alternative 2. All Solid wastes associated with
Alternative 3 would be managed in accordance with applicable state and federal handling and disposal
regulations. Transportation activities would be completed in accordance with applicable state and
federal requirements, by licensed and permitted haulers. Injection of bioremediation chemicals would
be performed in accordance with North Carolina requirements for injection control.
11.2 PRIMARY BALANCING CRITERIA
"Hie following five criteria are used to evaluate the overall effectiveness of a particular remedial
alternative:
¦ Long-term Effectiveness mid Permanence.
¦ Reduction of T M Y of Contaminants through Treatment.
¦ Short-term Effectiveness.
¦ Implementability. and
¦ Cost.
11.2.1 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment overtime, once clean-up levels have
been met. This criterion includes the consideration of residual risk that will remain onsite following
remediation and the adequacy and reliability of controls.
Triangle Pacific IROD
11-3
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11.2.1.1 Surface Soil
Alternative 2. Excavation and Off-Site Disposal, provides some degree of long-term protection.
Alternative 2, removes the highest levels of soil contamination from the Site. No long-term pollutant
emissions, impacts to water, ecology, or community are anticipated for Alternative 2,
11.2.1.2 Grmm dwater
Alternatives 2 and 3 provide some degree of long-term protection. There are no long-term human or
community impacts associated with the implementation of any of the three alternatives.
11.2.2 Reduction of T/MA through Treatment
Reduction of T M V through treatment refers to the anticipated performance of the treatment
technologies that may be included as part of the remedy,
/ /. 2.2.1 Surface Soil
Alternative 2 does not include treatment to reduce T M Y of COCs in soil.
11.2.2.2 Grotui dwater
Although insufficient to be conclusive, data obtained during the RI indicate there are groundwater
conditions (low oxygen, reducing) at the Site that are conducive to very limited biological degradation
of TCE. Very low concentrations of the reductive dechlorination of TCE (eis-l,2-DCE. trans- 1.2-DCE.
and vinyl chloride) indicate that this process is occurring slowly under nominal conditions. Based on
this, reduction of T M V of TCE could occur under each of the groundwater remedial alternatives.
Alternative 3 includes an active treatment process that would enhance and accelerate natural attenuation
in the treatment zone beyond what is anticipated for the other three remedial alternatives.
11.2.3 Short-Term Effectiveness
Short-term effectiveness addresses the period needed to implement the remedy and any adverse impacts
that may be poised to workers, the community, and the environment during construction and operation
of the remedy until cleanup levels are achieved.
11.2.3.1 Surface Soil
Alternative 2 would negatively impact the environment and community in the short term due to
increased construction traffic during excavation activities. However, minimal pollutant emissions,
impacts to water, ecology, or community are anticipated. Higher fuel use greenhouse gas emissions,
associated v\ ith the operation of construction equipment and off-site shipping, are anticipated with
Alternative 2. Physical hazards relating to the movement of heavy equipment and vehicles associated
with remedial construction activities would be anticipated. Chemical hazards related to Site COC s in
dust and surface runoff would be anticipated and controlled appropriately during excavation. Safety
equipment and personal protective equipment would protect workers from exposure. Proper
construction controls will be implemented to minimize environmental and community impact.
.Anticipated nuisance conditions associated with Alternativ e 2 include dust and noise generation, runoff,
and additional traffic due to construction equipment. Proper construction controls would be
implemented to prov ide community protection.
Triangle Pacific IROD
11-4
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11,2.3.2 Groun dwater
There are no short-term human or community impacts associated with the implementation of
Alternatives 2 or 3. Short-term impacts associated with physical hazards to workers and the community,
as well as impacts from emissions, would be addressed for Alternative 3 through accepted health and
safety and construction practices. There would be some short-term environmental and sustainability
impacts associated with the implementation Alternative 3, Specifically, construction activities would
generate greenhouse gases (emissions from vehicles) and consume fossil fuel. Green remediation
techniques would be considered to reduce the short-term impacts of the remedy,
11.2.4 Inipleiiieiitability
Implementability addresses the technical and administrative feasibility of a remedy from design through
construction and operation. Factors such as availability of services and materials, administrative
feasibility, and coordination with other government entities are also considered.
/ /. 2.4.1 Surface Soil
Alternative 2 is readily implemented. Potential for additional on-site traffic due to construction
equipment could impact the day-to-day activities of one of the current site owners. TCOM.
I J. 2.4.2 Groun dwater
Alternatives 2 and 3 are readily implementable and necessary specialists and materials are readily
available. No difficulties are anticipated related to instituting ICs. The treatment technology in
Alternative 3 is readily eonstruetible. and equipment, materials, and specialists are readily available,
although a treatability study w ould be required to verify effectiveness. Effectiveness of remediation
included in Alternative 3 is easily monitored. Because of disruption to on-going business activities and
nuisance to neighboring residences. Alternative 3 is more difficult to implement than .Alternative 2.
11.2.5 Cosl
"111 is criterion assesses the cost of an alternative in terms of total present worth cost. Budgetary cost
estimates were prepared for each alternative, based on vendor information and quotations, cost
estimating guides, and experience. Budgetary cost estimates were prepared for the purpose of
alternatives comparison, and were based on site-specific information, when available. The budgetary
cost estimates include capital costs, annual O&M costs, periodic O&M costs, and present worth cost.
The present worth cost for these alternatives was calculated for the expected duration of the remedy
using the current Office of Management & Budget discount rate of 7°®.
Table 11-3 summarizes the costs associated with each alternative.
11.3 MODIFYING CRITERIA
State and community acceptance are modifying criteria that shall be considered in selecting the RA,
11.3.1 State Support Agency Acceptance
"Hie State of North Carolina, as represented by NCDEQ. was actively involved in the development and
review of the FS report and the Interim Proposed Plan. NCDEQ has been actively involved in the
Triangle Pacific IROD
11-5
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development and review of the RI. FS. and the cleanup plan for the Site, The State supports the
preferred alternatives selected. See Appendix D for the State's December 14. 2017 correspondence
related to the ROD,
11.3.2 Community Acceptance
Written comments were received during the public comment period and a few were expressed during the
Proposed Plan public meeting. Refer to Section 3.0 of the Responsiveness Summary (Appendix E).
Hie Proposed Plan was placed in the Information Repositories and the Proposed Plan Information Fact
Sheet was distributed to interested residents, to local newspapers and radio and TV stations, and to local.
State, and Federal officials on April 17, 2018. The Proposed Plan public meeting was held on the
Tuesday evening. May 8. 2018. The public comment period on the Proposed Plan began May 8, 2018
and closed on June 7. 2018.
Triangle Pacific IROD
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12.0
PRINCIPAL THREAT WASTES
Principal threat wastes (PTWs) are highly toxic or highly mobile materials that may present a significant
risk to human health or the environment if exposure were to occur. They include liquids and other
materials Inning high concentrations of toxic compounds (for example, solvents). Consistent with the
NCP and EPA guidance. the identification ol principal threats is made on a site-specific basis.
There were no site human health risks for the anticipated industrial land use exceeding 1E-3 cancer risk;
as a result. PTV was not observed at the Site. The interim action selected for groundwater utilizes in
situ treatment for TCE,
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13.0 SELECTED REMEDY
The Interim Action for this Site includes the following cleanup alternatives:
¦ For contaminated surface soil, the preferred option is Alternative S-2 - Alternative 2, Excavation
and Off-Site Disposal
¦ For contaminated groundwater, the selected alternative is Alternative GW-3 - Groundwater
Enhanced Bioremediation and ICs
It is anticipated that interim soil and groundwater response actions will be implemented in phases. The
recommended phasing is listed below. It is expected that some of these phases can proceed on
simultaneous tracks.
Phase
Action
I
Establishment of ICs
II
Excavation of surficial soil to address unacceptable ecological risk from direct contact
with COCs. Excavated soil will be sampled to determine if disposition at a RCRA C,
RCRA D or TSCA disposal facility is required.
III
Supplemental Ecological Risk Assessment. A follow-up ecological risk assessment
will be conducted at the Site, after the interim soil response action is implemented to
determine if a CERCLA response is needed to address residual contamination. A
follow-up decision document will be issued to document the decision after a Proposed
Plan.
rv
Conduct the Enhanced Bioremediation Treatability Study. Evaluate potential
enhancements that would be effective for treating TCE at this Site.
V
Implementation of Enhanced Bioremediation. Focusing on the area surrounding MW-
03 will accelerate the degradation of TCE and address potential unacceptable risk from
ingestion of groundwater. Enhanced Bioremediation will also create a biologically
active area on the downgradient edge of the TCE plume, further limiting the potential
for TCE migration to off-site surface water and groundwater POEs.
The interim soil response action will address soil with the highest COC concentrations. A supplemental
risk assessment will be conducted at the Site, after the interim soil response action is implemented to
determine if a CERCLA response is needed to address residual contamination.
13.1 SUMMARY OF THE RATIONALE FOR THE SELECTED REMEDY
The selected interim remedy addresses the two primary risks at the Site; to future residential
groundwater users, and, ecological receptors' exposure to contaminated soils. The alternative selected
for groundwater remediation should remove the majority of the groundwater TCE contamination that is
present above regulatory levels in the treatment area of the plume. The NC 2L cleanup level, or ARAR,
for TCE is 3 ug/L. Remaining levels of TCE above NC 2L standards and MCLs, as well as any other
COCs above NC 2L standards or MCLs will be addressed in the final ROD. The excavation and disposal
of the two surface soil areas exhibiting unacceptable ecological risk will be conducted, and the area will
then be compared to ecological cleanup criteria to determine if other areas require action as part of the
final ROD.
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13.2 DESCRIPTION OF THE SELECTED REMEDY
A detailed description of the alternatives: surface soil Alternative 2 and groundwater Alternative 3 can
be found in Sections 10.1.1.2 and 10.1.2.3, respectively.
13.3 SUMMARY OF ESTIMATED REMEDY COSTS
The present value for the selected remedy is $1,353,149. This is based on a capital cost of $1,055,474
and an annual O&M of $297,674. This cost information summarized in the table below is based on the
best available information regarding the anticipated scope of the remedial alternative. Changes in the
cost elements arc likely to occur as a result of new information and data collected during the engineering
design of the remedial alternative. Major changes may be documented in the form of a memorandum in
the Administrative Record file, an Explanation of Significant Difference, or a ROD .Amendment. This is
an order-of-magnitude engineering cost estimate that is expected to be within +5 to -30 percent of the
actual project cost.
COST SUMMARY FOR THE PREFERRED ALTERNATIVES
Description of Alternative
Capital
Costs
Net Present Worth
of Operation and
Maintenance
Total Net
Present Worth
of Alternative
Surface Soil
Alternative 2
Excavation mid Disposal in a
Commercial Facilitv
$ 151.050
$0
$ 151.050
Groundwater
Alternative 3
Groundwater Enhanced
Bioremediation and
Institutional Controls
$ 904.424
$ 297,674
$1,202,099
$1,055,474
$ 297.674
$1,353,149
13.4 EXPECTED OUTCOME OF THE SELECTED REMEDY
The goal of surface soil Alternative 2 is to remove all soils with contaminants above the soil cleanup
levels (to be determined). .After the soil hot spot remediation effort, the chemical quality of the
underlying groundwater should be protected from further contamination from the Triangle Pacific
property and the property may be reused w ith unlimited use and unrestricted exposures, if the follow-up
aggregate ecological assessment shows no more concerns. The enhanced bioremediation Alternative 3
will remediate most of the contamination in the groundwater under the property. Both alternatives will
reduce the T M V of the contamination associated with the Site.
13.4.1 Available Land Use After Cleanup
The preferred soil remedy will impact the use of the property during the actual implementation of the
soil cleanup. The soil phase of the cleanup should be completed in one to two months. Implementation
of the groundwater remediation phase will have minimum impact on land use as all injections associated
w ith this alternative can be completed bgs. All physical structures (wells, etc.) associated w ith this
alternative can be completed so that the structures are Hush with ground level (i.e.. no structures sticking
above the ground surface). Injection activities should be completed within two weeks. "Hie Agency
anticipates achieving unlimited use mid unrestricted exposure throughout the area of the plume, given
sufficient time.
Triangle Pacific IROD
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13.4.2 Filial Clean-Up Levels
Section 9 lists the groundwater clean-up level for TCE under this IROD. The NC 2L cleanup level, or
ARAR. for TCE is 3 ug L. Ecological-risk based soil cleanup levels will be documented in the final
ROD for the Site,
13.4.3 Anticipated Environmental and Ecological Benefits
This Site is not located next to a sensitive ecological environment, nor has this Site impacted the any
ecological environment. Source removal from "hot spot' areas of the Site with elevated concentrations of
COCs will be of benefit to the ecological receptors of the Site, It is anticipated that the removal of
YOCs for the adversely impacted aquifer will have significant environmental benefit. No additional
environmental or ecological benefits are anticipated from this interim action.
Triangle Pacific IROD
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14.0
STATUTORY DETERMINATIONS
14.1 PROTECTION OF HI MAN HEALTH AND THE ENVIRONMENT
Tliis interim action will be protective of human health and the environment from the identified exposure
pathways in the short term. The ARARs identified in Tables 21, 22, and 23 all focus on the
implementation of the preferred soil remedy which includes excavation, transportation, and disposal of
contaminated soils at an EPA approved off-site permitted facility mid the injection of materials into the
underlying aquifer to promote enhance in situ bioremediation (i.e., bioactive /one where the microbial
population w ill mineralize the contaminants in the groundwater to harmless, non-hazardous by-
products).
14.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
Section 121(d) of CERCLA. as amended, specifies, in part, that RAs for cleanup of hazardous
substances must comply with requirements and standards under federal or more stringent state
environmental laws and regulations that are ARARs to the hazardous substances or particular
circumstances at a site or obtain a waiver. See also 40 C.F.R. § 30Q.430(f)( 1 )(ii)(B). ARARs include
only federal and state environmental or facility siting laws regulations and do not include occupational
safety or worker protection requirements. Compliance w ith Occupational Safety and Health
Administration (OSHA) standards is required by 40 C.F.R. § 300.150 and therefore the CERCLA
requirement for compliance with or wavier of ARARs does not apply to OSHA standards. For purposes
of ease of identification, the EPA has created three categories of ARARs: Chemical-. Location-, and
Action-Specific. Under 40 C.F.R. § 300.400(g)(5). the lead and support agencies shall identity their
specific ARARs for a particular site and notify each other in a timely manner as described in 40 C.F.R. §
300.515(d).
Under CERCLA Section 121(e)(1). federal, state, or local permits are not required for the portion of any
removal or RA conducted entirely on-site as defined in 40 C.F.R. § 300.5. See also 40 C.F.R. §§
300.400(e)( 1) & (2). Also. CERCLA actions must only comply with the "substantive requirements." not
the administrative requirements of a regulation. Administrativ e 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 for determining compliance with certain requirements such as those typically identified as
Location-Specific ARARs. 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 mav be useful in developing CERCLA remedies. See 40 C.F.R. §
300.400(g)(3).
The Federal and State Chemical-specific ARARs along with any TBCs that are relevant to the Selected
Remedy are presented in Table 14-1. The Federal and State Action-specific ARARs along w ith any
TBCs that are relevant to the Selected Remedy are presented in Table 14-2. Hie Federal and State
Location-specific ARARs along with any TBCs that are relevant to the Selected Remedy are presented
in Table 14-3. The selected remedy will comply with all ARARs in these tables that are listed as either
"Applicable" or "Relevant and Appropriate". No waiver to any ARAR is anticipated at this time.
Triangle Pacific IROD
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14.3 COST EFFECTIVENESS
Tliis section explains how the selected interim action meets the statutory requirement that all Soperfund
remedies be cost-effective. A cost-effective remedy in the Superfund program is one whose "costs are
proportional to its overall effectiveness" (NCP §3G0.430(f)(l)(ii)(D)). Hie "overall effectiveness" is
determined by evaluating the following three of the five balancing criteria used in the detailed analysis
of alternatives: (1) Long-term effectiveness and permanence: (2) Reduction in toxicity, mobility, and
volume: and (3) Short-term effectiveness. "Overall effectiveness is then compared to cost" to determine
whether a remedy is cost-effective (NCP §300.430(f)(l)(ii)(D)).
The final determination of cost-effectiveness will be presented in the final ROD.
The assessment of cost-effectiveness of the selected remedy is presented in a matrix in Table 14-4. For
each alternative, information was presented on long-term effectiveness and permanence, reduction in
toxicity, mobility, and volume through treatment, and short-term effectiveness. The iiiformation in
those three categories was compared to the prior alternative listed and evaluated as to whether it was
more effective, less effective or of equal effectiveness. The selected remedy is considered cost effective
because it is a permanent solution that reduces human health and ecological risks to acceptable levels at
than other alternatives evaluated.
14.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
(OR RESOURCE RECOVERY) TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
EPA has determined that the selected interim action, although not designed or expected to be final,
provides the best balance of trade-offs in terms of the five balancing criteria, while considering the
statutory preference for treatment as a principle element, bias against off-site treatment and disposal, and
consideration of state and community acceptance. This interim action w ill allow the Agency to remov e
the continuing source of contamination to the groundwater as well as begin remediating the plume.
14.5 PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT
The excavation and off-site disposal of contaminated soils required by this interim action does not
involve treatment therefore this segment of the alternative dos not meet the statutory preference for
treatment. However. Enhanced Bioremediation does involve treatment of contaminants found in the
groundwater mid soil therefore this portion of the selected alternative does meet the statutory preference
for treatment. Although soil Alternative 2 does not involve treatment, the two areas exhibiting
unacceptable ecological risk will be removed, and the area w ill then be compared to ecological cleanup
criteria to determine if other areas need to be addressed as part of the final ROD. Soil Alternative 1.
would not reduce or remove the unacceptable ecological risk.
14.6 FIVE-YEAR REQUIREMENTS
A review (in accordance with 40 CFR 300,430(f)(4)(ii)) is required, at minimum every five years if a
remedy is selected that results in hazardous substances, pollutants, or contaminants remaining at the Site
above levels that allow for unlimited use and unrestricted exposure. Because the selected interim action
w ill not achieve levels that allow for unlimited use and unrestricted exposure w ithin five years. EPA w ill
conduct five-year reviews in accordance w ith EPA policy until cleanup levels established in this ROD
are attained or a final ROD is in place. Reviews will begin fine years after initiation of the RAs to help
ensure that the selected remedy is protective of human health and the environment.
Triangle Pacific IROD
14-2
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15.0 DOCUMENTATION OF SIGNIFICANT CHANGES FROM PREFERRED
ALTERNATIVE OF PROPOSED PLAN
There are no notable changes made between the April Interim Action Proposed Plan and this IROD.
Triangle Pacific IROD
15-1
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16.0 REFERENCES
Harris. W.I I. and Wilder. H.B.. 1966. Geology and Ground -water Resources of the Hertford-Elizabeth
City Area North Carolina. Groundwater Bulletin No. 10, North Carolina Department of Water
Resources.
Pasquotank County. March 1989. The Pasquotank County Subdivision Ordinance.
Greenhome & O Mara. Inc.. June 1990. Phase I Screening Site Investigation of Triangle Pacific
Corporation. NCD 0S~336SS5. June 1990. for the State of North Carolina Department of Environment.
Health and Natural Resources, Division of Solid Waste Management, Superfimd Section.
North Carolina Department of Environment and Natural Resources (NCDENR) 2013. North Carolina
and EPA Criteria. Available online at:
http: portaI.ncdeiu-.org c document library get_file?uuid=dfc89f23-
a372-4782-b3b0-60e6884bl696&groupId=38364. Updated May 2013.
O'Brien & Gere Engineers. Inc. (OBG). 2018. Feasibility Study. Former Triangle Pacific Corporation
Site. Elizabeth City. North Carolina. April 6, 2018
OBG. 2015. Remedial Investigation Report. Former Triangle Pacific Corporation Site. Elizabeth City.
North Carolina. January 2015.
United States Army Corps of Engineers (USACE). 2013. Environmental Residue Effects Database.
Available online at: http: el.erdc.usace.amiy.mil ered .
United States Environmental Protection Agency (EPA). 2013a. Region 3 Freshwater and Marine
Benchmarks. Biological Technical Assistance Group. World Wide Web link:
www .epa.gov reg3hwmd risk eco index.htm
EPA, 2013b. National Recommended .Ambient Water Quality Criteria. Office of Water. Office of
Science and Technology. Available online at:
http: w ater.epa.gov seitech swguidance standards criteria current index.cfm.
EPA. 2013c. ProUCL Version 5. Statistical Software Package.
EPA, 2003a. Ecological Soil Screening Level (Eco-SSLs) Guidance and Documents. Available online
at: www.epa.gov pswer riskassessment ecorisk ecossl.htm, November 2003.
EPA. 2001. Supplemental Guidance to RAGS: Region 4 Bulletins. Ecological Risk Assessment.
Originally Published November 1995. Website version last updated November 2001. Available online at
www.epa.gov region4 superfimd programs riskassess ecolbul.html.
EPA, 1998. Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Ground
Water. EPA Office of Research and Development. EP.A600 R-98 128, September 1998.
EPA, 1996. ECO Update: EcoTOX Thresholds. EPA 540-F-95-038. Office of Solid Waste and
Emergency Response. Washington. D.C, January 1996.
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APPENDIX A
Figures
-------
FIGURE 1-1
Pailin Creek
Newbegun Creek
dits Source: Esri, DigitalGlobe, GeoEye, Earthstar
iS/Airbus DS; USDA, USGS, AeroGRID, IGN, and theGIS
« j Site Boundary
MAP LOCATION
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
SITE LOCATION
1,000 2,000
65841
11/20/2017
1:18,000
O'BRIEN & GERE ENGINEERS, INC.
-------
FIGURE 1-2
e
<
s>
Ł
8
ro
>
S9
ss
E
8
CO
>
LEGEND
_I Rankin Realty Property
" ¦ Site Boundary
Areas From Previous Investigations
USEPA Designated Areas
Groundwater Plume Area
Approximate Drum Location
FORMER TRIANGLE PACIFIC SITE
FEASIBILITY STUDY
ELIZABETH CITY, NC
SITE LAYOUT AND
AREAS OF INTEREST
65841
11/20/2017
O'BRIEN & GERE ENGINEERS, INC.
Drum
Tar-Stained
Boiler House/
Coal Storage Area
Drum Areas
WWTP
Drum Areas
Landfill
Former Blimp Tether
USEPA Area Designations
A-Storage Tank Area
B-Wooded Area NW of Landfill
C-WWTP and Incinerator
D- On-Site Landfill
E-Coal Storage Area (Field South
of Boiler House)
F-Field North of Wooded Area
f- Former Fuel Island Area
G- Areas Surrounding the Blimp
Hanger
Stacker Building
AMS Corporation
Refueling Area
I
Storage Tank-Area
' Former
Municipal Works Building
Boi er House
Former Cistern
Hangar Building
Pump House and Water Tower
Newbegun Creek
-Ir
Newbegun Creek
Sen/ice Layer Credits: Source: Esri, DiyitalGlobe. GeoEye, Earthstar
Geographies. CNES/Airbus DS USD A, USGS, AeroGRID, IGN, and the GIS
User Community 1
-------
FIGURE 1-3
Newbegun Creek
Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar
Geographies, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid,
IGN, IGP, swisstopo, and the GIS User Community
2
a.
&
&
§
q
LEGEND FORMER TRIANGLE PACIFIC SITE
1 i Site Boundary ELIZABETH CITY, NC * Based on "Core Land Use
- - - Plan for Pasquotank
Agriculture County and Elizabeth City"
industrial (January 2012)
"L PASQUOTANK COUNTY ZONING*
Residential-25A
0 1,000 2,000
65841
11/27/2017 Feet O'BRIEN & GERE ENGINEERS, INC.
-------
s>
5
BH-26:
BHI18
FIGURE 4-1
-(j)- Rl Soil Boring
Anticipated Soil
Sample Location
Approximate Extent
of Soil Removal
J Site Boundary
ESTIMATED EXTENT OF
SURFACE SOIL REMOVAL
nh
*
J rm r
Vsti
X
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
0
250 500
1,000
Feet
65841
11/21/2017
\This document wasdeveloped in colorfRepmductjon^B^^may^no^^ptvsentU^
O'BRIEN & GERE ENGINEERS, INC.
-------
FIGURE 4-2
s>
Ł
ig
8
Q
SffU
M Proposed MNA Locations
• Estimated Injection Grid
Total Chlorinated VOC Cone, (ng/l)
1-9
10-99
100-999
TRIANGLE PACIFIC
ELIZABETH CITY, NC
ESTIMATED INJECTION GRID FOR
IN SITU ENHANCED BIOREMEDIATION
330
65841
11/27/2017
O'BRIEN & GERE ENGINEERS, INC.
-------
FIGURE 5-1
V
o
(ft
\
' V
Newbegun Creek
Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar
Geographies, CNES/Airbus DS. USDA, USGS, AeroGRID, IGN, and the GIS
User Community
o.
5
E
-------
FIGURE 5-2
NOVEMBER 4, 2011
AY 19-20, 1998
FEBRUARY 3, 2012
'
_
AUGUST 18, 2014
LEGEND
NOVEMBER 1,2012
A Deep Monitoring Well
A Monitoring Well
E Staff Gauge
Groundwater Contour (ft. msl)
Inferred Groundwater Contour (ft. msl)
! ! Site Boundary
Service Layer Credits: Source: Esn,
DigitalGlobe, GeoEye, Earthstar Geographies,
CNES/Airbus DS, USDA, USGS, AeroGRID,
IGN, and the GIS User Community
W I R
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
HISTORICAL GROUNDWATER
POTENTIOMETRIC SURFACE
65841
11/27/2017
O'BRIEN & GERE ENGINEERS, INC.
-------
Figure 5-3
Human Health Conceptual Site Model
Former Triangle Pacific Site
Elizabeth City, North Carolina
Chemical
Source
Migration
Pathways
Exposure/ Transport Media
Exposure Routes
Former Triangle
Pacific Facility -
Historical
Manufacturing
Operations
Infiltration/
Percolation
Surface Soil
(0-1 foot bgs)
Leaching~^
Incidental Ingestion
Dermal Contact
Ambient Inhalation of Particulates/ Vapors
Volatilization
Subsurface Soil
(1-10 feet bgs)
Leaching f
Incidental Ingestion
Dermal Contact
Ambient Inhalation of Particulates/ Vapors
Volatilization
Groundwater
Stormwater Runoff
Recharge / Discharge
Surface Water
Equilibrium partitioning
Surface Water
Fish Tissue
Surface Sediment
(0-0.5 feet bgs)
Crab Tissue
Surface Sediment
(0-0.5 feet bgs)
Indoor Inhalation of Vapors
Incidental Ingestion
Dermal Contact
Ambient Inhalation of Vapors
Indoor Inhalation of Vapors
Incidental Ingestion
Dermal Contact
Ingestion
Ingestion
Incidental Ingestion
Dermal Contact
Human Receptors
On-Site Receptors
Off-Site Receptors
Industrial Worker
Utility/Sewer Line
Worker
Construction
Worker
Adolescent
T respasser
Adult T respasser
Older Child
Swimmer
Adult Swimmer
Child Fish/Crab
Consumer
Older Child
Recreational Angler
Adult Recreational
Angler
Current |Future
Current |Future
Future
Current |Future
Current | Future
Current |Future
Current |Future
Current |Future
Current |Future
Current |Future
•
•
•
•
•
•
•
•
•
0
0
0
0
0
0
0
0
0
0
•
•
•
•
•
•
•
•
•
0
0
0
0
0
0
0
0
0
0
•
•
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
¦
¦
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
A
A
A
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
A
A
A
0
0
0
0
0
0
0
0
0
0
0
0
0
0
¦
¦
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
•
•
•
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
•
•
•
0
0
0
0
0
0
0
0
0
A
A
A
A
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•
•
•
•
0
0
0
0
0
0
Notes:
• : Potentially complete exposure pathway. Scenario evaluated quantitatively in the human health risk assessment (HHRA).
¦ : Scenario evaluated through comparison of media concentrations to the NCDENR IHSB vapor intrusion screening levels.
A: Pathway is considered de minimis.
0 : Incomplete exposure pathway.
-------
Chemical Source
Migration
Pathways
Transport/Primary
Exposure Media
Figure 5-4
Former Triangle-Pacific Corporation Site
Ecological Conceptual Site Model
Elizabeth City, North Carolina
Secondary Exposure
Media
Exposure Routes
Ecological Receptors
Terrestrial
Aquatic/Semi-Aquatic
Terrestrial Plants
Soil Invertebrates
Mammalian
Insectivore
(Short-tailed Shrew)
Mammalian Omnivore
(Raccoon)
Avian Omnivore
(American Robin)
Avian Carnivore
(Red-tailed Hawk)
Benthic Invertebrates
SZ
(/)
Ll
Mammalian Carnivore
(River Otter)
Avian Piscivore
(Great Blue Heron)
Former Triangle
Pacific Facility -
Historical
Manufacturing
Operations
Notes:
• : Potentially complete exposure pathway. Scenario will be evaluated quantitatively in the Baseline Ecological Risk Assessment (BERA).
A : Minor pathway that does not contribute significantly to overall risk. Scenario will be evaluated qualitatively in the BERA.
0 : Incomplete exposure pathway.
NA: Not applicable
bgs - below ground surface
NA
0
0
0
0
0
A
A
•
•
0
0
0
0
0
0
•
•
A
A
NA
0
•
•
•
•
0
0
•
•
0
0
A
A
A
A
0
0
A
A
NA
0
0
0
0
0
A
A
•
•
0
0
0
0
0
0
•
•
0
0
NA
0
0
0
0
0
A
A
•
•
NA
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
NA
0
0
0
0
0
NA
NA
0
0
NA
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
NA
0
0
0
0
0
NA
NA
0
0
NA
0
•
•
•
•
0
0
0
0
NA
A
•
•
•
•
0
0
0
0
•
•
A
A
A
A
0
0
0
0
NA
A
A
A
A
A
NA
NA
0
0
-------
H®
Figure 5-5
MW-13
MW-03D MW:03
MW-15D
wahm
MW-16D
MW-08
MW-06
MW-05
This document was developed in color. Reproduction in B/W may not represent the data as intended.
Legend
A Monitoring Well
A Deep Monitoring Well
Site Boundary
TRIANGLE PACIFIC
ELIZABETH CITY, NC
GROUNDWATER
MONITORING NETWORK
11/25/14
47733
OBRIENGGERE
-------
FIGURE 5-6
Chlorinated VOCs Detected in
Groundwater Samples
No Chlorinated VOCs Detected in
Groundwater Samples
Chlorinated VOCs Detected in
Groundwater Screening Samples
No Chlorinated VOCs Detected in
Groundwater Screening Samples
Cross-Section Lines
' i Site Boundary
Total Chlorinated VOC Cone, (pg/l)
1-9
10-99 o
100-999
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
IN
A
SUMMARY OF CHLORINATED
VOCS IN GROUNDWATER
65841
11/27/2017
O'BRIEN & GERE ENGINEERS, INC.
-------
FIGURE 5-7
SOUTH
CO
NORTH
D'
10
-- 0
---10
o -20-
Ł
LU
—I
LU
-40-
LEGEND
-50-
Ł23 CLAY
mi SILTY SAND - SANDY SILT
| | SAND
[22 CLAYEY SAND
O fill
-i- WATER TABLE (02/03/12)
CHLORINATED COMPOUNDS ESTIMATED ISOCONCENTRATIONS (pg/L)
158 CONCENTRATION OF CHLORINATED COMPOUNDS (pg/L)
4' TEMPORARY WELL SCREEN
--20
-30
--40
-50
10' PERMANENT WELL SCREEN
SECTION D-D'
SCALE: HORIZ. 1"=120' 120'
120'
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
CHLORINATED VOCs IN
GROUNDWATER
SECTION D-D'
VERTICAL EXAGGERATION IS 12:1
FILE NO 10679.65841-001
NOVEMBER 2017
O'BRIEN & GERE ENGINEERS, INC.
-------
FIGURE 5-8
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cd
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122 CLAY
im SILTY SAND - SANDY SILT
j | SAND
YZA CLAYEY SAND
ra fill
J- WATER TABLE (02/03/12)
CHLORINATED COMPOUNDS ESTIMATED ISOCONCENTRATIONS (pg/L)
158 CONCENTRATION OF CHLORINATED COMPOUNDS (|jg/L)
10' PERMANENT
WELL SCREEN
SECTION E-E'
SCALE: HORIZ. 1"=120' 120'
120'
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NC
CHLORINATED VOCs IN
GROUNDWATER
SECTION E-E'
VERTICAL EXAGGERATION IS 12:1
FILE NO 10679.65841-002
NOVEMBER 2017
O'BRIEN & GERE ENGINEERS, INC.
-------
APPENDIX B
Tables
-------
Table 5-la
Constituents in Soil Above Remedial Investigation Screening Levels
Triangle Pacific Site
Elizabeth City, North Carolina
Metals
NC PSRG
Protection of
Groundwater
(mg/kg)
NC PSRG
Industrial,
Health Based
(mg/kg)
EPA industrial
(mg/kg)
Arsenic
5.8
3
3
Barium
*
44,000
22,000
Cadmium
*
200
98
Cobalt
0.9
70
35
Copper
*
9,400
4,700
Iron
150
100,000
82,000
Manganese
*
5,200
2,600
Lead
*
800
800
Vanadium
6
1,200
580
Zinc
*
70,000
35,000
SVOCs
Benzo(a)anthracene
*
2.9
2.9
Benzo(a)pyrene
*
0.29
0.29
Benzo(b)fluoranthene
*
2.9
2.9
Benzo(k)fluoranthene
*
29
29
Chrysene
*
290
290
Dibenz(a,h)anthracene
*
0.29
0.29
lndeno(l,2,3-cd)pyrene
*
2.9
2.9
PCBs
Aroclor-1254
*
—
1
Aroclor-1260
*
—
1
Pesticides
| 4,4-DDT
*
8.6 8.6 |
Notes: mg/kg - microgram per kilogram; NC PSRG - North Carolina Preliminary Soil Remediation Goal, September
2014 (the final ROD will provide constituents in soil above current NC PSRGs); EPA Industrial - USEPA Region III
Risk Based Screening Levels for Industrial Soil, May 2014; PCBs - Polychlorinated Biphenyls; SVOCs - Semi-
Volatile Organic Compounds; — Screening value not available in 2014; * - Constituent concentrations in
groundwater did not exceed North Carolina groundwater standards. Cobalt and iron were not identified as
constituents exceeding Industrial NC PSRGs, but were in groundwater above North Carolina groundwater
standards and in soil above PSRGs for Protection of Groundwater.
Page 1 of 1
-------
Table 5-lb
Constituents in Groundwater Above Remedial Investigation Screening Levels
Triangle Pacific Site
Elizabeth City, North Carolina
Metals
Hg/L
Source
Arsenic
10
NC2L
Cobalt
1
NC IMACs
Iron
300
NC2L
Vanadium
0.3
NC IMACs
VOCs
Hg/L
Source
1,2-Dichlorobenzene
20
NC2L
1,4-Dichlorobenzene
6
NC2L
Trichloroethene
3
NC2L
Vinyl Chloride
0.03
NC2L
Pesticides
Hg/L
Source
Total Chlordane
0.1
NC2L
Dieldrin
0.002
NC2L
Notes: ng/L - microgram per liter; NC 2L - North Carolina groundwater standards identified in 15A NCAC 2L, Last Amended on April 1, 2013; NC
IMACs - North Carolina Interim Maximum Allowable Concentrations, Last Amended on April 6, 2018; VOCs - Volatile Organic Compounds.
Page 1 of 1
-------
Table 5-2a - Summary of Current Soil Analytical Results
for Wastewater Treatment Plant Area
VOCs and SVOCs
Triangle Pacific, Elizabeth City, NC
USEPA Region III
Wastewater Treatment Plant Area
BH-14
BH-19
BH-20
BH-22
BH-23
BH-24
BH-25
BH-26
USEPA Region III
USEPA Region III
Risk Based
BH-14-01
BH-19-01SD
BH-20-01
BH-22-01
BH-23-01
BH-24-01
BH-24-02
BH-25-01
BH-26-01
Risk Based
Risk Based
Screening Levels -
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
Screening Levels
NC PSRG
Screening Levels
NC PSRG
Soil to
NC PSRG Soil to
10/25/2011
10/10/2012
10/26/2011
10/9/2012
10/9/2012
10/9/2012
10/9/2012
10/9/2012
10/9/2012
Analyte/Parameter
CAS Number
Industrial Soil1
Industrial Soil
Residential Soil1
Residential Soil
Groundwater1
Groundwater
Duplicate Pair
VOCs
2-Butanone
19,000
28,000
2,700
5,400
0.12
16
< 0.004
< 0.019
<0.01
< 0.005
< 0.004
< 0.004
0.006 J
< 0.007
<0.01
Acetone
67-64-1
6,100
100,000
67,000
12,000
0.29
24
< 0.007
< 0.033
0.38
0.032
0.014 J
0.042 J
0.15 J
< 0.012
< 0.016
Isopropylbenzene
98-82-8
190
270
990
270
0.074
1.3
< 0.001
< 0.005
< 0.003
R
< 0.001
< 0.001J
0.41 J
< 0.002
< 0.002
Methylene chloride
75-09-2
57
640
1,000
57
0.0029
0.023
< 0.002
< 0.009
0.008 J
< 0.003
< 0.002
< 0.002
< 0.002
< 0.004
< 0.005
Styrene
100-42-5
600
870
3,500
870
0.13
0.92
< 0.001
< 0.005
0.009 J
R
< 0.001
< 0.001
< 0.001
< 0.002
< 0.002
SVOCs
1,1-Biphenyl
92-52-4
20
40
4.7
9.4
0.00086
43
<0.19
<0.49
<0.25
0.084
0.056
< 0.022
<0.021
<0.02
<1.3
2-Methylnaphthalene
91-57-6
300
600
23
46
0.019
1.6
0.031
0.014
< 0.0093J
0.77
0.74
0.0082
0.011
0.0046 J
0.88
Acenaphthene
83-32-9
4,500
9,000
350
700
0.55
8.4
< 0.0076
0.0025 J
< 0.0093J
0.019 J
0.0091 J
0.00088 J
0.0016 J
< 0.0008
6.8
Acenaphthylene6
208-96-8
4,500
-
350
-
0.55
21
0.0039 J
0.012
< 0.0046J
0.052
0.014 J
0.029
0.045
0.00047 J
0.53
Acetophenone
98-86-2
12,000
2,500
780
1,600
0.058
3.5
<0.19
<0.49
<0.25
0.043
<0.02
< 0.022
0.04 J
<0.02
<1.3
Anthracene
120-12-7
23,000
46,000
1,700
3,400
5.8
660
0.0076 J
0.021
< 0.0046J
0.054
0.015 J
0.013
0.02
0.00082 J
16
Benzaldehyde
100-52-7
120,000
1,200
780
1,200
0.043
3
<0.76
< 1.9J
<0.99
0.23
< 0.079J
0.11 J
0.28 J
<0.08
<5.11
Benzo[a]anthracene
56-55-3
2.9
2.9
0.15
0.15
0.012
0.18
0.014 J
0.07
0.024 J
0.21**
0.059
0.024
0.052
0.0034
100
Benzo[a]pyrene
50-32-8
0.29
0.29
0.015
0.015
0.004
0.059
0.011 J
0.091 J**
0.024 J
0.2
0.043
0.04
0.063
0.0035
100
Benzo[b]fluoranthene
205-99-2
2.9
2.9
0.15
0.15
0.041
0.6
0.31 J
0.14 J
0.043 J
0.38
0.09
0.073
0.099
0.0074
190
Benzo[g,h,i]perylene
191-24-2
-
-
-
-
-
7,800
0.036 J
0.022 J
0.012 J
0.11
0.047
0.016
0.02
0.0027
24
Benzo{k]fluoranthene
207-08-9
-
-
-
-
-
7,800
0.082 J
0.052 J
0.018 J
0.15
0.026
0.028
0.051
0.0031
63
bis(2-Ethylhexyl)Phthalate
117-81-7
160
160
38
38
1.3
7.2
73
9.1
4.4
1.2
0.096 J
0.52
0.59
6
68
Carbazole
86-74-8
-
-
-
-
-
0.37
<0.19
<0.49
<0.25
0.042
<0.02
<0.022
<0.021
<0.02
4.8
Chrysene
218-01-9
290
290
15
15
1.2
18
0.048
0.041
0.029 J
0.37
0.099
0.044
0.071
0.0033 J
96
Dibenz[a,h]anthracene
53-70-3
0.29
0.29
0.015
0.015
0.013
0.19
0.012 J
0.0083 J
< 0.0093J
0.041
0.015 J
0.0046
0.0062
0.00093 J
11
Dibenzofuran
132-64-9
100
200
7.2
14
0.015
5.2
<0.19
<0.49
<0.25
0.18
0.15
< 0.022
< 0.021
<0.02
2.1 J
Dimethyl Phthalate
131-11-3
-
-
-
-
-
-
0.78 J
<1.9
<0.99
< 0.083
< 0.079
< 0.086
< 0.085
<0.08
<5.1
di-n-Octyl Phthalate
117-84-0
820
1600
62
120
57
38
R
< 1.9
<0.99
< 0.083
< 0.079
< 0.086
< 0.085
<0.08
<5.1
Fluoranthene
206-44-0
3,000
6,000
230
460
8.9
330
0.026
0.086
0.047 J
0.35
0.07
0.065
0.096
0.005
160
Fluorene
86-73-7
3,000
6,000
230
460
0.54
56
< 0.0076
0.0025 J
0.011 J
0.037
0.018 J
< 0.00086
0.0033
< 0.0008
4.2
lndeno[l,2,3-cd]pyrene
193-39-5
2.9
2.9
0.15
0.15
0.24
2
0.028 J
0.024 J
0.011 J
0.085
0.021
0.014
0.018
0.0022
31
Naphthalene
91-20-3
17
17
3.8
3.8
0.00054
0.21
0.039
0.029
< 0.0093J
0.41
0.49
0.006
0.011
0.0034 J
0.94
Nitrobenzene
98-95-3
22
22
5.1
5.1
0.000092
-
<0.19
<0.49
<0.25
< 0.021
<0.02
< 0.022
< 0.021
<0.02
<1.3
Phenanthrene
85-01-8
-
-
-
-
-
68
0.031
0.04
0.018 J
0.71
0.34
0.02
0.028
0.0061 J
58
Phenol
108-95-2
25,000
50,000
1,800
3,600
0.33
0.23
<0.19
1.3
<0.25
< 0.021
<0.02
< 0.022
<0.021
<0.02
<1.3
Pyrene
129-00-0
2,300
4,600
170
340
1.3
220
0.027
0.13
0.035 J
0.27
0.076
0.089
0.17
0.0042
150
All units are in mg/kg.
Notes
USEPA - United States Environmental Protection Agency
PSRG - Preliminary Soil Remediation Goal
bgs - below ground surface
- Screening value not available.
B - The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D - Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated
R - Data rejected during validation.
JN - The analysis indicates the presence of an analyte that has been "Tentatively Identified" and the associated numerical value represents its approximate concentration.
NA - The sample was not analyzed for the specific constituent.
ND - Constituent not detected. No detection limit available.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise.
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance.
2 - Alpha-chlordane and gamma-chlordane have been totaled and compared to the chlordane screening values.
3 - Analysis for hexavalent chromium indicated that concentrations of hexavalent chromium were below detection limits for all samples. As such, chromium at the site
is assumed to consist primarily of trivalent chromium and screening levels for trivalent chromium were applied.
4 - Benzo(b)fluoranthene and benzo(k)fluoranthene are undifferentiated for this sample.
5 - Sccreening levels for endosulfan used.
6 - No risk-based screening levels exist for acenapthylene. Risk-based screening levels used here are for acenapthene.
** - Primarily, screening levels are most stringent for the Soil to Groundwater Category, and become less stringent for the Residential Soil and Industrial Soil Categories,
respectively. Standards for some constituents, however, do not follow this pattern. As such, a detected value that exceeds a higher standard in a lower Screening Category may be
flagged according to the highest Screening Category to reflect the highest amount of hazard.
Constituent exceeds an Industrial Screening Level
Constituent exceeds a Residential Screening Level
Constituent exceeds a Soil to Groundwater Screening Level
1/19/2015
Page 1 of 1
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Report\Tables 11-2014\
Table 10_Summary of Soil Analytical Results for Wastewater Treatment Plant Area.xls| Table 10 VOC and SVOC
-------
Table 5-2b - Summary of Current Soil Analytical Results
for Wastewater Treatment Plant Area
Pesticides/PCBs/Metals/Cyanide
Triangle Pacific, Elizabeth City, NC
USEPA Region III
Wastewater Treatment Plant Area
BH-14
BH-15
BH-16
BH-17
BH-18
BH-19
BH-20
BH-22
BH-23
BH-24
BH-25
BH-26
USEPA Region III
USEPA Region III
Risk Based
BH-14-01
BH-14-02
BH-14-03
BH-15-01
BH-15-02
BH-15-03
BH-16-01
BH-16-02
BH-16-03
BH-17-01
BH-17-02
BH-17-03
BH-18-01
BH-19-01SD
BH-20-01
BH-22-01
BH-23-01
BH-24-01
BH-24-02
BH-25-01
BH-26-01
Risk Based
Risk Based
Screening Levels -
0-0.5" bgs
1-2' bgs
2-4' bgs
0-0.5' bgs
1-2' bgs
2-4' bgs
0-0.5' bgs
1-2' bgs
2-4' bgs
0-0.5' bgs
1-2' bgs
2-4' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5' bgs
0-0.5" bgs
Screening Levels
NC PSRG
Screening Levels
NC PSRG
Soil to
NC PSRG Soil to
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/25/2011
10/24/2011
10/24/2011
10/24/2011
10/26/2011
10/10/2012
10/26/2011
10/9/2012
10/9/2012
10/9/2012
10/9/2012
10/9/2012
10/9/2012
Analyte/Parameter
CAS Number
Industrial Soil
Industrial Soil
Residential Soil1
Residential Soil
Groundwater1
Groundwater
Duplicate Pair
Pesticides
4-4-DDD
72-54-8
9.6
9.6
2.2
2
0.0072
0.24
< 0.019
< 0.00039
< 0.00039
0.027 JN
< 0.00039
< 0.00041
0.003 JN
0.19
0.0096
0.0014 J
< 0.00039
< 0.0004
< 0.013
< 0.032
< 0.0093
0.038
< 0.00039
0.0039
0.0043
0.0043
0.14 J
4-4-DDE
72-55-9
6.8
6.8
1.6
1.6
0.054
0.24
0.26
0.011
0.0031 JN
0.24
0.00067 J
0.0015 J
0.046
0.26
0.016
0.0024 JN
0.00051 J
< 0.0004
1.8
0.120
0.085
0.8
0.0037
0.022
0.027
0.019
2.6
4-4-DDT
50-29-3
8.6
8.6
1.9
1.9
0.077
0.34
< 0.019
< 0.024
< 0.0039
0.34
0.00098 J
0.0022
0.059
0.53
0.018
0.0019 J
< 0.00039
<0.0004
5.5
< 0.050
< 0.093
0.22
< 0.00039
0.031
0.038
0.045
3.9
alpha-BHC
319-84-6
0.37
0.37
0.085
0.085
0.000041
0.00036
< 0.0097
< 0.0002
< 0.0002
<0.002
< 0.0002
< 0.00021
< 0.00019
< 0.00022
< 0.00021
< 0.00022
< 0.0002
< 0.0002
0.13
< 0.0025
< 0.00024
< 0.00021
< 0.0002
< 0.00022
< 0.00022
< 0.0002
0.019 JN
Aldrin
309-00-2
0.14
0.14
0.031
0.031
0.00075
0.0033
< 0.034
0.0035 J
0.0058
<0.01
< 0.0002
< 0.00021
0.00036 J
0.0023 J
< 0.00021
< 0.00022
< 0.0002
< 0.0002
0.49 JN
< 0.0025
0.0017
< 0.00021
< 0.0002
< 0.00022
< 0.00022
< 0.0002
0.023 JN
alpha-Chlordane
5103-71-9
-
-
-
-
-
-
< 0.0097
< 0.0002
< 0.0002
0.034
< 0.0002
< 0.00021
0.00044 J
0.031
0.0023
< 0.0011
< 0.0002
< 0.0002
< 0.0068
0.0058 J
< 0.0081
<0.00021
< 0.0002
< 0.00022
0.00065 J
< 0.0002
0.038 J
gamma-Chlordane
5103-74-2
-
-
-
-
-
0.1S
0.0072
<0.002
<0.002
<0.0002
0.00043 J
0.0012 J
0.036
0.0025
< 0.00022
< 0.0002
< 0.0002
1.2
< 0.0076
0.026
0.0031 J
0.00099
< 0.00022
< 0.00022
< 0.0002
< 0.031
Total Chlordane
57-74-9
8
8
1.8
1.8
0.015
0.068
<0.23
< 0.0048
< 0.0048
<0.048
< 0.0047
< 0.0049
0.006 J
0.17
0.015 J
< 0.0052
< 0.0047
< 0.0048
<0.16
< 0.058
< 0.0056
<0.07
< 0.0047
< 0.0052
< 0.0051
< 0.0048
<0.38
delta-BHC
319-86-8
-
-
-
-
-
—
<0.026
< 0.00054
0.00067 J
< 0.0054
< 0.00053
< 0.00055
< 0.00052
0.0012
< 0.00055
< 0.00058
< 0.00053
< 0.00054
0.049
< 0.0065
0.0038
< 0.00056
< 0.00053
< 0.00058
< 0.00057
<0.00054
< 0.0068
Dieldrin
60-57-1
0.14
0.14
0.033
0.033
0.000069
0.00081
< 0.019
< 0.0015
0.0084 JN
<0.004
< 0.00039
< 0.00041
< 0.0019
< 0.00043
< 0.0004
0.0019 J
< 0.00039
<0.0004
<0.31
< 0.0048
< 0.0063
< 0.00065
< 0.0004
< 0.00053
0.00044 J
< 0.0004
< 0.095
Endosulfan Is
959-98-8
490
980
37
74
0.14
5.6
< 0.013
0.00087 J
< 0.0032
< 0.0026
< 0.00026
0.00035 J
< 0.00025
0.0023 JN
0.00033 J
< 0.0011
< 0.00026
< 0.00026
0.14
< 0.0032
< 0.00031
< 0.00027
< 0.00026
< 0.00028
< 0.00028
< 0.00026
< 0.0033
Endosulfan II
33213-65-9
490
980
37
74
0.14
5.6
<0.019
< 0.00039
< 0.00039
<0.004
< 0.00039
< 0.00041
0.00078 J
< 0.00043
< 0.0004
< 0.00043
< 0.00039
< 0.0004
< 0.013
< 0.0048
< 0.00046
< 0.00041
< 0.00057
0.00089 J
< 0.00042
< 0.0004
< 0.0081
Endosulfan Sulfate
1031-07-8
490
-
37
0.14
8
< 0.097
<0.002
0.0073 JN
0.027 JN
0.00074 J
< 0.00041
< 0.0019
0.0081 JN
< 0.0021
0.0012 J
< 0.00039
<0.0004
<0.28
< 0.0048
< 0.0078
< 0.00041
< 0.00039
< 0.00043
< 0.00042
<0.0004
0.029 J
Endrin
72-20-8
25
50
1.8
3.6
0.92
0.81
< 0.019
<0.02
< 0.00039
0.064 JN
< 0.00039
< 0.00041
0.0038 JN
0.013 J
< 0.0021
< 0.00043
< 0.00039
< 0.0004
< 0.013
< 0.0073
< 0.019
< 0.0082
0.0024
< 0.00043
< 0.00042
< 0.0004
<0.05
Endrin Aldehyde
7421-93-4
-
-
-
-
-
—
<0.019
< 0.0025
< 0.00039
<0.02
< 0.00039
< 0.00041
< 0.00038
< 0.00043
0.00062 J
< 0.00043
< 0.00039
< 0.0004
0.47
< 0.0048
< 0.0045
0.0028 JN
0.0015 J
< 0.00043
< 0.00042
< 0.0004
< 0.014
Endrin Ketone
53494-70-5
-
-
-
-
-
-
< 0.034
< 0.00071
0.0022 JN
< 0.0072
< 0.00071
< 0.00074
< 0.00069
0.0034 JN
< 0.00073
< 0.00077
< 0.0007
< 0.00072
<0.14
< 0.0087
< 0.0061
< 0.00075
< 0.00071
< 0.00077
< 0.00076
< 0.00072
< 0.009
Heptachlor
76-44-8
0.51
0.51
0.12
0.12
0.00016
0.0066
< 0.0097
< 0.0002
< 0.0002
<0.002
< 0.0002
< 0.00021
< 0.00019
< 0.00022
< 0.00021
< 0.00022
< 0.0002
< 0.0002
< 0.0068
< 0.0025
< 0.0012
< 0.0015
0.00052 J
< 0.00022
< 0.00022
< 0.0002
0.01 J
Heptachlor Epoxide
1024-57-3
0.25
0.25
0.059
0.059
0.000078
0.00082
<0.047
< 0.0002
< 0.00099
<0.002
< 0.0002
< 0.00021
< 0.00019
< 0.00022
0.00042 J
0.00072 J
0.00024 J
< 0.0002
< 0.033
< 0.018
< 0.0012
< 0.00021
< 0.0002
< 0.00022
< 0.00022
< 0.00079
< 0.061
Lindane
58-89-9
2.5
2.5
0.56
0.56
0.00024
0.0018
< 0.0097
< 0.0002
< 0.0002
0.0098 J
< 0.0002
< 0.00021
< 0.00095
< 0.0011
< 0.00021
< 0.00022
< 0.0002
< 0.0002
< 0.0068
< 0.0025
0.00042 J
< 0.00036
< 0.00023
< 0.00022
< 0.00022
< 0.0002
< 0.0056
PCBs
Aroclor-1254
11097-69-1
1
-
0.24
-
0.01
-
8.8
0.66
1
0.73
< 0.0039
<0.004
0.095 J
0.57 JN
0.058
< 0.0042
< 0.0038
< 0.004
110
1.7
0.41 J
< 0.021
< 0.0039
< 0.0043
< 0.0042
0.031 J
<1.5
Aroclor-1260
11096-82-5
1
-
0.24
-
0.027
-
<0.37
<0.02
< 0.039
0.38 J
< 0.0039
<0.004
< 0.019
< 0.021
0.024
0.01 J
< 0.0038
<0.004
<3.3
<0.140
<0.11
<0.11
< 0.0058
< 0.0063
< 0.0063
0.023 J
<0.4
Metals
Aluminum
7429-90-5
110,000
100,000
7,700
15,000
3,000
-
28,200
39,200
15,100
16,900
37,900
37,500
16,400
19,300
36,600 J
19,000
18,300
19,400
17,100
12,000 J
19,800
21,700 J
25,000 J
21,300 J
25,200 J
15,900 J
17,900 J
Antimony
7440-36-0
47
94
3.1
6.2
0.035
0.9
0.155 J
< 0.0871 UJ
< 0.0864 UJ
0.394 J
< 0.0869 UJ
< 0.0867 UJ
< 0.0839 UJ
0.769 J
0.178 J
0.301 J
< 0.0859 UJ
< 0.0888 UJ
14.5 J
5.49 J(-)
0.564 J
0.628 J(-)
0.0854 J(-)
0.124 J(-)
0.0918 J(-)
< 0.079D
2.11 J(-)
Arsenic
7440-38-2
3
3
0.67
0.67
0.0015
5.8
S.68J
5.04 J
7.8 J**
6.97 J**
4.19 J
2.62 J
4.71 J
21.6 J**
6.79 J**
6.05 J**
4.8 J
3.77 J
127 J**
4.14
3.77 J
8.44**
6.02 **
3.72
3.7
3.13
30**
Barium
7440-39-3
22,000
44,000
1,500
3,000
16
580
161 J
156 J
59.4 J
123 J
132 J
84.3 J
51.9 J
52.9 J
128 J
120 J
95.9 J
89.6 J
507
97.3
117
142
79.7
62.4
65.5
34.7
329
Beryllium
7440-41-7
230
460
16
32
1.9
63
1.08 J
0.886 J
0.569 J
0.712 J
0.848 J
0.528 J
0.408 J
0.44 J
0.782 J
0.887 J
0.74 J
0.684 J
0.395 J
0.281 J
0.493 J
1.11
0.526
0.382
0.439
0.273
0.921
Cadmium
7440-43-9
98
200
7
14
0.069
3
< 0.0496
< 0.0518
< 0.0514
0.634 J
< 0.0517
< 0.0515
< 0.0499
0.0963 J
0.17 J
0.198 J
< 0.0511
< 0.0528
60.6 J
3.19
1.08 J
0.913
0.0247 J
0.0939 J
0.0698 J
0.0977 J
1.97
Calcium
7440-70-2
-
-
-
-
-
-
1,170 J
1,620 J
1,400 J
1,1800 J
2,310 J
3,040 J
555 J
586 J
807 J
5,160 J
1,980 J
1,580 J
14,500 J
5,120
2,910 J
3000
486
748
659
952
16900
Chromium 3
16065-83-1
180,000
100,000
12,000
24,000
4,000,000
360,000
54.9 J
43.9 J
35.7 J
28.8 J
38.9 J
40.1 J
26.2 J
91 J
45.2 J
27.7 J
27 J
21.5 J
250 J
36.6
30.8 J
25.8
22.7
25.1
22.1
16
39.5
Cobalt
7440-48-4
35
70
2.3
4.6
0.027
0.9
4.12
5
3.24
3.21
4.24
4.01
2.88
3.44
4.54
3.44
2.95
3.25
10.8
2.66 J
2.94
5.2
3.36
3.02
3.25
3.09
4.14
Copper
7440-50-8
4,700
9,400
310
620
2.8
700
12 J
10.7 J
10.5 J
22.1 J
8.25 J
11.3 J
7.78 J
38 J
13.7 J
9.77 J
6.47 J
5.91 J
649
133
63.7
32.8
6.34
4.69
4.67
6.09
66
Iron
7439-89-6
82,000
100,000
5,500
11,000
35
150
15,400
17,100
13,800
13,500
15,000
14,400
12,500
21,800
22,300
16,000
11,200
11,400
357,000
11,900
15,600
11,900
11,900
11,700
11,400
7,040
12,700
Lead
7439-92-1
800
800
400
400
-
270
85.3
20.3
37.3
90.3
13.7
11.8
9.91
562
84.2
30.5
9.58
7.89
685
257
157
92.5
14.4
49.2
29
8.25
496
Magnesium
7439-95-4
-
-
-
-
-
2,020 J
2,920 J
2,150 J
1,800 J
1,920 J
3,470 J
1,550 J
2,130 J
1,820 J
1,440 J
2,060 J
2,100 J
3,470
1,090
2,280
1,810
1,610
1,530
1,480
1,710
3,550
Manganese
7439-96-5
2,600
5,200
180
360
2.8
65
136
116
89.1
190
90.6
78.1
67.8
66.3
86.9
181
121
127
1110
86.8
71.8
156
67.5
64.7
64.8
95.7
356
Mercury
7439-97-6
4
3.1
0.94
1.9
0.33
1
0.293
0.0815 J
0.082 J
0.147 J
0.0526 J
0.0345 J
0.0441 J
0.558
0.0734 J
0.0697 J
0.0424 J
0.0183 J
0.289 J
0.148 J
0.211 J
0.314
0.0451 J
0.0655 J
0.0679 J
0.0291 J
0.379
Nickel
7440-02-0
2,200
4,400
150
300
2.6
130
19.9 J
22.8 J
17.2 J
12.5 J
20.8 J
19.6 J
13.9 J
16.5 J
23.2 J
14.6 J
13.2 J
11.9 J
182 J
16.5
20.8 J
14.3
11.5
11.1
11.2
9.09
16.1
Potassium
7440-09-7
-
-
-
-
-
-
1,260 J
1,460 J
1,350 J
1,450 J
1,340 J
1,270 J
979 J
1,120 J
1,320 J
1,270 J
1,020 J
764 J
1,100 J
635
1,270 J
1,060
835
814
857
741
1,310
Selenium
7782-49-2
580
1,200
39
78
0.052
2.1
0.422 J
0.159 J
0.134 J
0.391 J
0.181 J
0.166 J
0.175 J
0.359 J
0.427 J
0.445 J
0.211 J
0.22 J
0.486 J
0.316 J
0.407 J
0.694 J
0.515 J
0.369 J
0.414 J
0.117 J
0.358 J
Silver
7440-22-4
580
1,200
39
78
0.08
3.4
0.0285 J
0.0299 J
0.0214 J
0.0967 J
0.0365 J
< 0.0166
0.0223 J
0.0616 J
0.0313 J
0.0598 J
0.037 J
0.0467 J
2.92 J
1.2
0.197 J
0.245
0.0256 J
0.0356 J
0.0257 J
< 0.024
0.816
Sodium
7440-23-5
-
-
-
-
-
-
117
303
309
129
158
250
58.2 J
66.2 J
81 J
127
120
321
2,860
40.5 J
151
104
53.7 J
45.4 J
41.6 J
37.6 J
144
Thallium
7440-28-0
1.2
2.4
0.078
0.16
0.0014
0.28
0.256
0.216 J
0.117 J
0.186 J
0.196 J
0.169 J
0.117 J
0.132 J
0.261
0.197 J
0.155 J
0.146 J
0.107 J
< 0.0875
0.208 J
0.204 J **
0.184 J **
0.179 J **
0.21 J **
0.0826 J **
0.17 J **
Vanadium
7440-62-2
580
1,200
39
78
8.6
6
40.6 J
49.3 J
37.6 J
27 J
42.6 J
47.3 J
30 J
34.8 J
54.2 J
33.1 J
30 3. J
24.9 J
25.7 J
18.2 J
24.1 J
27.6 J
27.8 J
27.6 J
27.8 J
17.7 J
39.7 J
Zinc
7440-66-6
35,000
70,000
2,300
4,600
37
1200
65.4 J
34.2 J
24.4 J
2,650 J
41.2 J
53.1 J
27.2 J
62.7 J
76.8 J
41.2 J
21.5 J
24.6 J
3,570
1,210
156
199
51
48.1
44.1
38.5
1,400
Cyanide
Cyanide
57-12-5
13
26
2.1
4.2
0.0015
14
<0.2
<0.21
<0.21
0.23 J
<0.21
<0.21
<0.21
0.62 J
0.22.
<0.22
<0.2
<0.21
0.771
0.560 J
<0.25
0.24 J
<0.21
<0.23
<0.23
<0.21
0.4 J
All units are in mg/kg.
Notes
USEPA - United States Environmental Protection Agency
PSRG - Preliminary Soil Remediation Goal
bgs - below ground surface
— Screening value not available.
8 - The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D - Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated.
R - Data rejected during validation.
JN — The analysis indicates the presence of an analyte that has been "Tentatively Identified" and the associated numerical value represents its approximate concentration
NA - The sample was not analyzed for the specific constituent.
ND - Constituent not detected. No detection limit available.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise.
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance.
2 - Alpha-chlordane and gamma-chlordane have been totaled and compared to the chlordane screening values.
3 - Analysis for hexavalent chromium indicated that concentrations of hexavalent chromium were below detection limits for all samples. As such, chromium at the site
is assumed to consist primarily of trivalent chromium and screening levels for trivalent chromium were applied.
4 - Benzo(b)fluoranthene and benzo(k)fluoranthene are undifferentiated for this sample.
5 - Sccreening levels for endosulfan used.
6 - No risk-based screening levels exist for acenapthylene. Risk-based screening levels used here are for acenapthene.
** - Primarily, screening levels are most stringent for the Soil to Groundwater Category, and become less stringent for the Residential Soil and Industrial Soil Categories,
respectively. Standards for some constituents, however, do not follow this pattern. As such, a detected value that exceeds a higher standard in a lower Screening Category may be
flagged according to the highest Screening Category to reflect the highest amount of hazard.
Constituent exceeds an Industrial Screening Level
Constituent exceeds a Residential Screening Level
Constituent exceeds a Soil to Groundwater Screening Level
1/19/2015
Page 1 of 1
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Reportables 11-2014\
Table 10_Summary of Soil Analytical Results for Wastewater Treatment Plant Area.xls|Table 10 Pest Metals
-------
Table 5-3 Well Construction Summary
Triangle Pacific Site
Elizabeth City, North Carolina
Ground
Total Well
Surface
TOC
Elevation
Depth from
Screened
Well
Elevation
Elevation
to Zero
Ground
Interval
Diameter
Material of
Well
(ft msl)
(ft msl)
(ft msl)
Surface (ft)
(ft bgs)
(in)
Construction
MW-1
5.32
7.82
N/A
15
5-15
2
PVC
MW-1D
5.34
8.00
N/A
35
25-35
2
PVC
MW-2
5.24
7.56
N/A
15
5-15
2
PVC
MW-3
5.18
7.55
N/A
15
5-15
2
PVC
MW-3D
5.28
8.00
N/A
35
25-35
2
PVC
MW-4
5.10
7.23
N/A
15
5-15
2
PVC
MW-5
5.60
7.93
N/A
15
5-15
2
PVC
MW-6
5.23
7.44
N/A
15
5-15
2
PVC
MW-7
8.50
11.26
N/A
15
5-15
2
PVC
MW-8
4.25
6.99
N/A
15
5-15
2
PVC
MW-9
7.25
9.97
N/A
15
5-15
2
PVC
MW-10
6.14
9.12
N/A
15
5-15
2
PVC
MW-11
4.99
7.89
N/A
15
5-15
2
PVC
MW-12
5.26
8.13
N/A
15
5-15
2
PVC
MW-13
6.09
8.82
N/A
15
5-15
2
PVC
MW-14
5.34
5.02
N/A
15
5-15
2
PVC
MW-15
5.03
8.10
N/A
15
5-15
2
PVC
MW-15D
5.03
7.59
N/A
35
25-35
2
PVC
MW-16
4.79
7.45
N/A
15
5-15
2
PVC
MW-16D
4.79
7.18
N/A
35
25-35
2
PVC
Staff Gauge
~
-
0.58
~
-
--
-
— Measurements not available for staff gauge
ft msl - Feet above mean sea level
ft bgs - Feet below ground surface
in - Inches
12/5/2014
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Report\Tables 11-2014\
Page 1 of 1 Table 1 - Well Construction Summary.xls
-------
Table 5-4 Historical Summary of Groundwater Elevations
Triangle Pacific, Elizabeth City, NC
Well
Depth to Water Below Top of Casing (ft)
Water Level Elevation (ft msl)
11/1/2011
11/4/2011
1/30/2012
2/3/2012
10/18/2012
11/1/2012
8/18/2014
11/1/2011
11/4/2011
1/30/2012
2/3/2012
10/18/2012
11/1/2012
8/18/2014
MW-1
8.02
7.95
5.94
6.08
9.13
6.70
8.96
-0.20
-0.13
1.88
1.74
-1.31
1.12
-1.14
MW-1D
Well Not Installed.
6.91
9.08
Well Not Installed.
1.09
-1.08
MW-2
7.72
7.67
5.72
5.81
8.82
6.48
8.52
-0.16
-0.11
1.84
1.75
-1.26
1.08
-0.96
MW-3
7.96
7.83
5.74
5.84
9.19
6.61
9.16
-0.41
-0.28
1.81
1.71
-1.64
0.94
-1.61
MW-3D
Well Not Installed.
6.71
9.32
Veil Not Installed.
1.29
-1.32
MW-4
N/A1
7.52
4.60
4.60
N/A1
N/A1 N/A1
N/A1
-0.29
2.63
2.63
N/A1
N/A1
N/A1
MW-5
7.92
7.66
7.34
7.49
8.39
7.59
8.55
0.01
0.27
0.59
0.44
-0.46
0.34
-0.62
MW-6
7.45
7.46
6.60
6.61
8.46
6.88
8.82
-0.01
-0.02
0.84
0.83
-1.02
0.56
-1.38
MW-7
11.35
11.24
10.38
10.29
12.11
11.32
11.75
-0.09
0.02
0.88
0.97
-0.85
-0.06
-0.49
MW-8
7.17
7.02
5.35
5.37
8.28
6.23
8.82
-0.18
-0.03
1.64
1.62
-1.29
0.76
-1.83
MW-9
10.10
9.96
8.40
8.37
11.16
9.29
11.01
-0.13
0.01
1.57
1.60
-1.19
0.68
-1.04
MW-10
9.27
9.14
8.34
8.30
10.05
9.00
NA3
-0.15
-0.02
0.78
0.82
-0.93
0.12
NA3
MW-11
7.87
7.66
7.24
7.35
8.40
7.72
8.65
0.02
0.23
0.65
0.54
-0.51
0.17
-0.76
MW-12
8.09
7.94
7.39
7.42
8.69
8.07
9.07
0.04
0.19
0.74
0.71
-0.56
0.06
-0.94
MW-13
9.03
8.98
6.91
7.04
10.32
7.69
10.23
-0.21
-0.16
1.91
1.78
-1.50
1.13
-1.41
MW-14
N/A1
5.11
3.43
2.68
6.06
4.25
5.32
N/A2
-0.09
1.59
2.34
-1.04
0.77
-0.30
MW-15
Wells Not Installed.
6.47
6.03
Wells Not Installed.
1.63
2.07
MW-15D
6.05
8.57
1.54
-0.98
MW-16
6.44
9.07
1.01
-1.62
MW-16D
6.19
8.67
0.99
-1.49
Staff Gauge
-
-
-
NM NM 0.80 0.08 1.44
NM
1.44
— Measurements not available for staff gauge
1 MW-4 was not accessible on 11/1/11, 10/18/12 and 11/1/12
2 MW-14 was not accessible on 11/1/11
3 MW-10 was unable to be located on 8/18/2014
NM Not Measured
ft msl feet mean seal level
1/19/2015
Page 1 of 1
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Report\Tables 11-2014\
Table 2 - Summary of Groundwater Elevations.xls
-------
Table 5-5a
Summary of Groundwater
Analytical Results 1998-2012
Triangle Pacific, Elizabeth, City, IMC
Analyte / Parameter
CAS Number
North Carolina
Groundwater
Quality Standards
and IMACs
USEPA Regional
Screening Level
for Tapwater1
MW-1
MW-01D
MW-3
MW-03D
MW-13
MW-15
MW-15D
MW-16
MW-16D
10/29/2012
10/29/2012
10/30/2012
10/30/2012
Duplici
10/30/2012
ate Pair
10/31/2012
10/31/2012
10/30/2012
10/31/2012
10/31/2012
VOCs
1,1-Dichloroethylene
75-35-4
350
28
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
0.9 J
<0.8
<0.8
1,2-Dichiorobenzene
95-50-1
20
30
<0.7
3 J
38
160
170
<0.7
<0.7
50
<0.7
<0.7
1,3-Dichlorobenzene
541-73-1
200
-
<1
<1
1J
4 J
4 J
< 1
< 1
< 1
< 1
< 1
1,4-Dichlorobenzene
106-46-7
6
0.48
< 1
< 1
3 J
12
12
< 1
< 1
3 J
< 1
< 1
Acetone
67-64-1
6,000
1400
<6
<6
<6
<6
< 6
< 6
7 J
17 J
<6
<6
cis-l,2-Dich!oroethylene
156-59-2
70
3.6
<0.8
<0.8
3 J
3 J
3 J
<0.8
<0.8
14
<0.8
<0.8
trans-1,2-Dichloroethylene
156-60-5
100
36
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
4 J
<0.8
<0.8
Trichioroethylene
79-01-6
3
0.49
< 1
< 1
110
250
250
< 1
< 1
180
< 1
< 1
Vinyl Chloride
75-01-4
0.03
0.019
< 1
< 1
< 1
< 1
< 1
< 1
< 1
11
< 1
< 1
SVOCs
4-Methylphenol | 106-44-5 | 40 1 190 1 <0.5 | <0.5 | <0.5 | <0.5 | <0.5 | <0.5 | 1 | < 0.5 | <0.5 | <0.5
Metals
Aluminum
7429-90-5
-
2,000
110 J
<6.5
<6.5
<6.5
<6.5
103
435
622
274
279
Arsenic
7440-38-2
10
0.052
2.6 J
41.4
<0.4
<0.4
<0.4
0.58
1.7 J
0.98 J
1.2
1.1
Barium
7440-39-3
700
380
30.6
11.2
31.6
15
13.4
50.6
21.8
32.4
40.7
16.6
Beryllium
7440-41-7
4
2.5
< 0.025
< 0.025
< 0.025
< 0.025
< 0.025
< 0.025
< 0.025
0.049 J
< 0.025
< 0.025
Cadmium
7440-43-9
2
0.92
0.51 J
< 0.082
< 0.082
< 0.082
< 0.082
< 0.082
0.094 J
0.094 J
< 0.082
< 0.082
Calcium
7440-70-2
-
2000
20,200 J
12,900 J
28,200 J
10,800 J
11,000 J
77,400
15,900 J
26,500 J
28,700
13,700
Chromium
7440-47-3
1
0.78
0.6SJ
<0.5
<0.5
<0.5
<0.5
0.51
0.67 J
1.3 J
0.63
1.1
Cobalt
7440-48-4
10
0.052
<0.66
6 J
1.2 J
1.6 J
1.5 J
<0.66
4.6 J
13.2
12.5
11.1
Copper
7440-50-8
700
380
6.7
<0.4
<0.4
<0.4
<0.4
1.9
0.6 J
0.52 J
1.6
1.4
Iron
7439-89-6
300
1,400
611J
10700 J
12.1 J
27.6 J
22.3 J
110
1720 J
572 J
502
430
Lead
7439-92-1
15
-
0.51 J
< 0.034
< 0.034
0.19 J
< 0.034
0.19
0.25 J
0.3 J
0.31
0.30
Magnesium
7439-95-4
-
-
2900 J
7100 J
16300 J
5390 J
5320 J
21800
7860 J
13100 J
15900
7020
Manganese
7439-96-5
50
43
300
1970
150
83.7
84.3
107
513
376
1970
469
Mercury
7439-97-6
1
0.063
<0.07
<0.07
0.09 J
<0.07
<0.07
< 0.070
<0.07
<0.07
<0.16
< 0.070
Nickel
7440-02-0
100
39
1.2 J
0.79 J
2 J
1.7 J
1.3 J
0.77
1.6 J
6.2
2.3
5.9
Potassium
7440-09-7
-
-
4,150
846
2,030
1,610
1,580
3,220
1,430
2,480
2,500
1,610
Selenium
7782-49-2
20
10
1.8 J
<0.5
0.95 J
0.59 J
0.63 J
0.99
<0.5
<0.5
<0.50
1.1
Sodium
7440-23-5
-
-
8,970 J
16,000 J
29,500 J
21,700 J
21,000 J
40,100
23200 J
32400 J
17100
22700
Vanadium
7440-62-2
0.3
8.6
3.3
<0.15
1.3
0.59 J
0.96 J
1.9
1.3
2.3
1.5
1.5
Zinc
7440-66-6
1,000
600
8 J
12.7 J
3.7 J
15 J
9.7 J
6.7
5.8 J
5.1 J
12.7
9.8
All values are in jjg/L.
Notes
USEPA- United States Environmental Protection Agency
IMAC — Interim Maximum Allowable Concentration.
— Screening value not available
B -The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D - Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance
2 - Screening levels for endosulfan used. Endosulfan 02L includes a mixture of alpha and beta isomers.
3 - Screening levels for chlordane used.
4 - Screening levels for endrin used. NC15 02L levels include endrin, endrin aldehde, and endrin ketone.
The result exceeds the North Carolina Groundwater Quality Standards and IMACs.
The result exceeds the USEPA RSL for tapwater.
1/19/2015
Page 1 of 4
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Report\Tab!es 11-2014\
Table 13-Summary of Groundwater Analytical Results 2012.xlsx| Oct 2012
-------
Table 5-5a
Summary of Groundwater
Analytical Results 1998-2012
Triangle Pacific, Elizabeth City, NC
Ana lyte/Para meter
CAS Number
North Carolina
Groundwater
Quality Standards
and IMACs
USEPA Regional
Screening Level
for Tapwater1
MW-01
MW-02
MW-03
MW-04
MW-05
MW-06
MW-07
MW-08
MW-09
MW-10
MW-11
MW-12
MW-13
MW-14
2/2/2012
2/2/2012
2/2/2012
2/2/2012
1/30/2012
1/30/2012
1/31/2012
1/31/2012
1/31/2012
1/30/2012
2/1/2012
2/1/2012
Duplic*
2/1/2012
te Pair
2/1/2012
2/2/2012
VOCs
1,2-Dichlorobenzene
95-50-1
20
30
1 <0.7
<0.7
22
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
1,3-Dichlorobenzene
541-73-1
200
-
<1
<1
2 J
<1
<1
<1
< 1
<1
<1
<1
<1
<1
<1
<1
< 1
1,4-Dichlorobenzene
106-46-7
6
0.48
<1
<1
4 J
<1
<1
<1
< 1
<1
<1
<1
<1
<1
<1
<1
<1
2-Butanone
78-93-3
4,000
560
1 <3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
26
24
<3
<3
Acetone
67-64-1
6,000
1,400
<6
<6
<6
<6
<6
<6
<6
<6
<6
<6
<6
28
27
<6
<6
Chloroform
67-66-3
70
0.22
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
1J
<0.8
cis-l,2-Dichloroethylene
156-59-2
70
3.6
<0.8
<0.8
1J
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
Trichloroethylene
79-01-6
3
0.49
< 1
<1
99
< 1
<1
< 1
< 1
<1
<1
<1
<1
<1
< 1
<1
<1
SVOCs
4-Methylphenol
106-44-5
40
190
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
0.6 J
13
15
<0.5
<0.5
2-Methylnaphthalene
91-57-6
30
3.6
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0096
0.017 J
0.012 J
< 0.0096
< 0.0096
0.018 J
< 0.0095
< 0.0095
< 0.0095
< 0.0095
0.015 J
Acenaphthene
83-32-9
80
53
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0096
< 0.0096
< 0.0096
< 0.0097
0.015 J
0.12
0.11
< 0.0095
0.33
Anthracene
120-12-7
2,000
180
< 0.0096
< 0.0096
0.011 J
< 0.0096
< 0.0096
< 0.0097
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
0.088
Fluoranthene
206-44-0
300
80
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
0.082
Fluorene
86-73-7
300
29
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0096
0.011 J
< 0.0096
< 0.0096
< 0.0096
0.016 J
0.066
0.13
0.088
< 0.0095
0.15
Naphthalene
91-20-3
6
0.17
0.058
0.11
0.041 J
0.038 J
0.061
0.1
0.048
0.087
0.06
0.1
0.097
0.04 J
0.052
0.035 J
0.093
Phenanthrene
85-01-8
200
-
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
< 0.029
0.046 J
0.064
0.059
< 0.029
0.27
Pyrene
129-00-0
200
12
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0096
< 0.0096
< 0.0096
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
0.053
Pesticides
4-4-DDD
72-54-8
0.1
0.031
< 0.0048
< 0.0047
< 0.0048
< 0.0048
< 0.0047
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0049
0.0055 J
< 0.0047
< 0.0047
< 0.0048
< 0.0048
Aldrin
309-00-2
0.002
0.0046
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019
0.0061 J
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019 UJ
<0.0019
< 0.0019
< 0.0019
alpha-Chlordane
5103-71-9
-
-
< 0.0019
0.38
< 0.0019
< 0.0019
0.0031 J
< 0.0019
< 0.0019
<0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019 UJ
0.0029 J
< 0.0019
< 0.0019
gamma-Chlordane
5103-74-2
_
_
< 0.00077
0.18
< 0.00076
< 0.00076
< 0.0016
< 0.0009
< 0.00077
< 0.00077
< 0.00076
<0.0011
< 0.0024
< 0.0041 UJ
< 0.0023
< 0.0096
< 0.00077
Total Chlordane
12789-03-6
0.1
0.22
<0.15
2.4
<0.15
<0.15
<0.15
<0.15
<0.15
<0.15
<0.15
<0.16
<0.15
< 0.15 UJ
<0.15
<0.15
<0.15
Dieldrin
60-57-1
0.002
0.0017
< 0.0051
0.011 J
<0.0051
< 0.0051
< 0.005
<0.0051
< 0.0051
< 0.0051
< 0.0051
< 0.0051
< 0.0051
< 0.005 UJ
< 0.005
< 0.0051
< 0.0051
Endosulfan I2
959-98-8
40
10
< 0.0041
0.057
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0042
< 0.0041
< 0.0041 UJ
< 0.0041
< 0.0041
< 0.0041
Endrin Ketone4
53494-70-5
2
0.23
< 0.0048
< 0.0047
< 0.0048
< 0.0048
< 0.0047
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0049
< 0.0048
< 0.0047 UJ
0.0061 J
< 0.0048
< 0.0048
Hexachlorobenzene
118-74-1
0.02
0.049
< 0.0029
< 0.0028
0.0034 J
< 0.0029
< 0.0028
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0028 UJ
< 0.0028
< 0.0029
< 0.0029
PCBs
Arocior-1248 | 12672-29-6 | 0.5 | 0.034 | <0.096 | 0.39 J | <0.095 | <0.095 | <0.094 | <0.094 ] <0.095 | <0.096 | <0.095 | <0.095 | <0.096 | <0.095 | <0.095 | <0.096 | <0.096
Metals
Aluminum
7429-90-5
-
2,000
86.8 J
49.9 J
23.1 J
52.7 J
18.8 J
20.6 J
<200
<200
<200
77.1 J
<200
81.7 J
64 J
115 J
56 J
Antimony
7440-36-0
1
0.78
< 0.42 UJ
< 0.42 UJ
< 0.42 UJ
1.1 J
0.66 J
0.57 J
<0.42
<0.42
<0.42
0.51 J
<0.42
< 0.42 UJ
< 0.42 UJ
< 0.42 UJ
< 0.42 UJ
Arsenic
7440-38-2
10
0.052
1 1J
< 0.95 UJ
< 0.95 UJ
< 0.95 UJ
1.8 J
24.8
27.7
<0.95
1J
51.8
286
190 J
195 J
< 0.95 UJ
37.4 J
Barium
7440-39-3
700
380
22.7 J
10.6 J
28.9 J
43 J
183 J
47.5 J
45.6
27.8
17.5
73.1 J
97.1
109 J
109 J
45.5 J
113 J
Calcium
7440-70-2
—
-
21800 J
31000 J
25400 J
55900 J
89600
62000
128000
55700
43500
92000
113000
123000 J
122000 J
72600 J
89600 J
Cobalt
7440-48-4
1
0.6
< 0.62 UJ
< 0.62 UJ
1.1 J
< 0.62 UJ
3.1 J
1.4 J
3.1 J
<0.62
0.68 J
5.4 J
18.7
10.3 J
10 J
< 0.62 UJ
1.3 J
Copper
7440-50-8
1,000
80
1.1 J
0.59 J
< 0.38 UJ
5.5 J
0.46 J
0.45 J
<0.38
<0.38
<0.38
0.58 J
<0.38
< 0.38 UJ
< 0.38 UJ
0.84 J
< 0.38 UJ
Iron
7439-89-6
300
1,400
556 J
42.3 J
29.2 J
55.9 J
1160
23800
24600
90.7 J
909
80900
96600
72200 J
72400 J
99.5 J
16200 J
Lead
7439-92-1
15
-
0.24 J
0.8 J
0.16 J
0.38 J
0.1 J
0.097 J
0.15 J
0.14 J
0.13 J
0.17 J
0.17 J
0.13 J
0.12 J
0.16 J
0.15 J
Manganese
7439-96-5
50
43
327 J
109 J
84.3 J
2 J
1390
1090
1150
17.7
185
1130
336
305 J
302 J
26.9 J
998 J
Magnesium
7439-95-4
—
—
4610 J
6630 J
15300 J
4390 J
47700 J
15200 J
9980
14700
28400
7480 J
22800
17800 J
17700 J
23200 J
11600 J
Mercury
7439-97-6
1
0.063
< 0.026
< 0.026
0.1 J
0.039 J
< 0.026
< 0.026
0.029 J
< 0.026
< 0.026
< 0.026
0.034 J
< 0.026
< 0.026
< 0.035
< 0.035
Nickel
7440-02-0
100
39
0.61 J
< 0.5 UJ
1.2 J
0.75 J
<0.5
<0.5
1.2 J
0.71 J
0.69 J
0.65 J
1.5 J
1.4 J
1.3 J
0.58 J
1.2 J
Potassium
7440-09-7
_
—
2010 J
2090 J
1840 J
3970 J
5760
3620
4760
6010
1010
4410
9820
10400 J
10300 J
2930 J
9690 J
Selenium
7782-49-2
20
10
0.86 J
1.4 J
0.89 J
0.36 J
<0.27
<0.27
<0.27
1.3 J
<0.27
<0.27
<0.27
< 0.27 UJ
< 0.27 UJ
1.4 J
< 0.27 UJ
Sodium
7440-23-5
-
—
13200 J
12600 J
24900 J
4430 J
19300
27500
7180
11700
9650
6220
7360
6700 J
6570 J
37200 J
22600 J
Vanadium
7440-62-2
0.3
8.6
2.4 J
0.87 J
0.85 J
2.2 J
0.73 J
0.67 J
0.62 J
1.2
0.72 J
1.5
1.2
1.5 J
1.3 J
1.7 J
1J
Zinc
7440-66-6
1,000
600
9.9 J
7.1 J
10.5 J
5.4 J
9.9 J
6.9 J 6.9 J
6.8 J
4.3 J
8 J
5.1 J
4.6 J
5.3 J
5.2 J
6.5 J
All values are in ng/L.
Notes
USEPA - United States Environmental Protection Agency
IMAC — Interim Maximum Allowable Concentration.
-- Screening value not available
B - The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D — Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise.
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance.
2 - Screening levels for endosulfan used. Endosulfan 02L includes a mixture of alpha and beta isomers.
3 - Screening levels for chlordane used.
4 - Screening levels for endrin used. NC15 02L levels include endrin, endrin aldehde, and endrin ketone.
The result exceeds the North Carolina Groundwater Quality Standards and IMACs.
The result exceeds the USEPA RSL for tapwater.
1/19/2015
Page 2 of 4
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\Rl\RI Report\Tables 11-2014\
Table 13 - Summary of Groundwater Analytical Results 2012.xisx| Feb 2012
-------
Table 5-5a
Summary of Groundwater
Analytical Results 1998-2012
Triangle Pacific, Elizabeth City, NC
Analyte/Parameter
CAS Number
North Carolina
Groundwater Quality
Standards and IMACs
USEPA Regional
Screening Level for
Tapwater1
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
MW-11
MW-12
MW-13
MW-14
11/2/2011
11/3/2011
11/2/2011
11/3/2011
11/2/2011
11/2/2011
10/31/2011
11/1/2011
10/31/2011
10/31/2011
11/1/2011
11/1/2011
Duplies
11/1/2011
te Pair
11/2/2011
11/3/2011
VOCs
1,2-Dichlorobenzene
95-50-1
20
30
<0.7
< 0.7 UJ
45
< 0.7 UJ
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
<0.7
< 0.7 UJ
1,3-Dichlorobenzene
541-73-1
200
-
<1
<1UJ
2 J
<1 UJ
< 1
<1
<1
<1
<1
<1
<1
< 1
<1
< 1
<1 UJ
1,4-Dichlorobenzene
106-46-7
6
0.48
<1
<1UJ
5
<1 UJ
< 1
<1
<1
<1
< 1
<1
<1
< 1
<1
<1
<1 UJ
Chloroform
67-66-3
70
0.22
<0.8
< 0.8 UJ
<0.8
<0.8 UJ
<0.8
<0.8
<0.8
1J
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
< 0.8 UJ
cis-l,2-Dichloroethylene
156-59-2
70
3.6
<0.8
<0.8
1J
< 0.8 UJ
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
<0.8
< 0.8 UJ
Trichloroethylene
79-01-6
3
0.49
< 1
<1UJ
95
<1 UJ
<1
<1
<1
< 1
<1
<1
<1
<1
<1
<1
<1UJ
SVOCs
4-Methylphenol
106-44-5
40
190
<0.5
<0.5
<0.5
<0.5
<0.5
R
<0.5
<0.5
0.5 J
4
1
3
2
<0.5
<0.5
2-Methylnaphthalene
91-57-6
30
3.6
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
0.022 J
< 0.0096
0.012 J
0.03 J
< 0.0095
< 0.0098
< 0.0096
0.018 J
0.021 J
Acenaphthene
83-32-9
80
53
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
< 0.0097
< 0.0096
< 0.0096 UJ
< 0.0096
< 0.0095
0.1
0.11
0.044 J
0.35
Acenaphthylene
208-96-8
200
-
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
< 0.0097
< 0.0096
< 0.0096 UJ
< 0.0096
< 0.0095
< 0.0098
< 0.0096
< 0.0096
0.018 J
Anthracene
120-12-7
2,000
180
< 0.0095
< 0.0097
0.02 J
< 0.0095
< 0.0095
< 0.0095
< 0.0097
< 0.0096
< 0.0096
< 0.0096
0.012 J
0.015 J
0.015 J
0.017 J
0.16
Fluoranthene
206-44-0
300
80
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
< 0.0097
< 0.0096
< 0.0096 UJ
< 0.0096
< 0.0095
< 0.0098
< 0.0096
0.031 J
0.054
Fluorene
86-73-7
300
29
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
0.022 J
< 0.0097
< 0.0096
< 0.0096 UJ
0.015 J
< 0.0095
0.075
< 0.0096
0.024 J
0.21
Naphthalene
91-20-3
6
0.17
< 0.028
0.15
0.036 J
0.038 J
< 0.028
< 0.028
0.09
< 0.029
0.038 J
0.051
0.051
0.039 J
< 0.029
0.066
0.064
Phenanthrene
85-01-8
200
-
< 0.028
< 0.029
< 0.028
< 0.028
< 0.028
< 0.028
< 0.029
< 0.029
< 0.029 UJ
< 0.029
< 0.029
0.059
0.059
0.086
0.15
Pyrene
129-00-0
200
12
< 0.0095
< 0.0097
< 0.0095
< 0.0095
< 0.0095
< 0.0095
< 0.0097
< 0.0096
< 0.0096 UJ
< 0.0096
< 0.0095
< 0.0098
< 0.0096
0.025 J
0.036 J
Pesticides
4-4-DDD
72-54-8
0.1
0.031
< 0.0048
0.023 J
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0049
< 0.0049
< 0.0048
alpha-Chlordane3
5103-71-9
0.1
0.22
< 0.0019
0.46
< 0.0019
< 0.0019
< 0.0019
0.0062 J
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.0019
< 0.002
< 0.002
< 0.0019
Chlordane
57-74-9
0.1
0.22
<0.11
4.4
<0.11
<0.11
<0.11
<0.11
<0.11
<0.12
<0.11
<0.12
<0.12
<0.12
<0.12
<0.12
<0.11
Endosulfan 1 2
959-98-8
40
10
< 0.0041
0.042 J
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0041
< 0.0042
< 0.0041
< 0.0041
< 0.0042
< 0.0041
< 0.0042
< 0.0042
< 0.0041
Endrin Ketone4
53494-70-5
2
0.23
< 0.0048
0.0075 J
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0048
< 0.0049
< 0.0049
< 0.0048
Heptachlor Epoxide
1024-57-3
0.004
0.0038
< 0.0022
0.13
< 0.0022
< 0.0022
< 0.0022
< 0.0022
< 0.0022
< 0.0022
< 0.0022
< 0.0022
< 0.0022
0.0025 J
0.0024 J
< 0.0023
< 0.0022
Hexachlorobenzene
118-74-1
0.02
0.049
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0029
0.0042 J
< 0.0029
< 0.0029
< 0.0096 UJ
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0029
< 0.0029
y-Chlordane3
5103-74-2
0.1
0.22
< 0.0023
0.46
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0023
< 0.0024
< 0.0023
Metals
Aluminum
7429-90-5
-
2,000
<200
58.7 J
<200
102 J
<200
<200
<200
230
<200
222
<200
<200
<200
254
44.1 J
Antimony
7440-36-0
1
0.78
< 0.42
< 0.42 UJ
<0.42
0.75 J
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
<0.42
Arsenic
7440-38-2
10
0.052
<0.95
< 0.95 UJ
<0.95
4.9
<0.95
<0.95
32.4
<0.95
<0.95
44.4
252
195
204
<0.95
35.1
Barium
7440-39-3
700
380
26.3
11.4 J
26.8
44.9
237
73.6
55.4
54.3
22.4
85.4
98.7
113
112
51
146
Calcium
7440-70-2
-
-
20500
30100 J
22000
40400
107000
79300
120000
55700
41100
84700
99500
114000
119000
70100
76600
Chromium
7440-47-3
10
0.0022
<0.6
< 0.6 UJ
<0.6
<0.6
<0.6
<0.6
<0.6
0.65 J
<0.6
0.63 J
<0.6
<0.6
<0.6
<0.6
<0.6
Cobalt
7440-48-4
-
0.6
0.9 J
<0.62
0.99 J
2.3 J
3.5 J
2.1 J
3 J
4.8 J
<0.62
8 J
15.8
8.8 J
8.5 J
0.69 J
1J
Copper
7440-50-8
1,000
80
1.2 J
<0.38 UJ
0.39 J
3.8 J
0.63 J
0.39 J
0.49 J
0.83 J
0.76 J
0.43 J
0.63 J
0.54 J
0.50 J
1.4 J
<0.38
Iron
7439-89-6
300
1400
210
58.6 J
19.4 J
919
1160
39700
32900
245
119 J
72100
87500
72800
74900
245
2610
Lead
7439-92-1
15
NS
0.14 J
0.78 J
<0.08
0.45 J
0.13 J
0.11 J
<0.08
0.21 J
0.14 J
0.22 J
0.13 J
0.21 J
0.14 J
0.19 J
0.11 J
Manganese
7439-96-5
50
43
216
182
90
49.1
1380
1400
875
1220
70.5
1070
283
269
263
51.1
1080
Magnesium
7439-95-4
-
-
5800
6310 J
12500
4030
64200
18200
7620
26600
31400
6920
20800
16100
16600
21600
13800
Mercury
7439-97-6
1
0.063
< 0.026
< 0.026 UJ
0.044 J
< 0.026
< 0.026
< 0.026
< 0.026
< 0.026
< 0.026
< 0.026
<0.026
<0.026
< 0.026
< 0.026
< 0.026
Nickel
7440-02-0
100
39
0.76 J
< 0.5 UJ
1.7 J
0.9 J
0.59 J
<0.5
1.3 J
2.5 J
2 J
2.3 J
1.6 J
1.7 J
1.8 J
1.4 J
1.5 J
Potassium
7440-09-7
-
-
2150
2330 J
1830
4020
6150
5150
5040
3170
1240
4350
9260
9590
9700
3240
8630
Selenium
7782-49-2
20
10
0.42 J
2 J
0.88 J
0.43 J
<0.27
<0.27
<0.27
0.73 J
0.58 J
<0.27
<0.27
<0.27
<0.27
1.6 J
<0.27
Sodium
7440-23-5
-
-
16800
11800 J
23600
11100
49800
40800
6010
15600
11000
7020
7290
6560
6,640
42100
21700
Vanadium
7440-62-2
0.3
8.6
1.4
1.1 J
0.94 J
3.1
0.69 J
0.45 J
0.59 J
1.5
1.7
1.5
1.1
1.4
1.2
2.2
2.8
Zinc
7440-66-6
1,000
600
14.2 J
14.7 J
6.3 J
10.6 J
7.1 J
14.3 J
8.1 J
8 J
14.3 J
7.7 J
7.1 J
15.3 J
7.4 J
10.6 J
16.8 J
All values are in ng/L.
Notes
USEPA - United States Environmental Protection Agency
IMAC - Interim Maximum Allowable Concentration.
- Screening value not available
B - The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D - Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise.
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance.
2 - Screening levels for endosulfan used. Endosulfan 02L includes a mixture of alpha and beta isomers.
3 - Screening levels for chlordane used.
4 - Screening levels for endrin used. NC15 02L levels include endrin, endrin aldehde, and endrin ketone.
The result exceeds the North Carolina Groundwater Quality Standards and IMACs.
The result exceeds the USEPA RSL for tapwater.
1/19/2015
Page 3 of 4
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\Rl\RI Report\Tables 11-2014\
Table 13 - Summary of Groundwater Analytical Results 2012.xlsx| November 2011
-------
Table 5-5a
Summary of Groundwater
Analytical Results 1998-2012
Triangle Pacific, Elizabeth City, NC
Analyte/Parameter
Sample ID
Depth (fbs)
Sample Date
CAS Number
North Carolina
Groundwater Quality
Standards and IMACs
USEPA Regional
Screening Level for
Tapwater1
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
1998
1998
Duplic
1998
ate Pair
1998
1998
1998
1998
Pesticides
Endrin
72-20-8
2
0.23
0.068 J
<0.10
<0.10 UJ
0.48 J
<0.10
2.2 D J
<0.10 UJ
Toxaphene
8001-35-2
0.03
0.015
<5.0
<5.0
<5.0 UJ
5.9
<5.0
35 D
<5.0 UJ
Metals
Aluminum
7429-90-5
~
2,000
1,700
678
634
158 B
219
1,370
514
Arsenic
7440-38-2
10
0.052
<1.3
<1.3
<1.3
<1.3
1.4 B
1.5 B
20.7
Barium
7440-39-3
700
380
<31.0
<14.6
<14.1
<22.1
<26.4
<13.7
147 B
Cobalt
7440-48-4
1
0.6
<2.9
<0.90
<0.90
2.2 B
22.1 B
2.2 B
10.8 B
Iron
7439-89-6
300
1,400
1,070
395
368
111
173
960
35,600
Lead
7439-92-1
15
-
<1.0
<1.0
<1.0
<1.0
<1.0
1.0 B
<1.0
Magnesium
7439-95-4
-
-
<7,970
<6,740
<6,650
<10,800
<8,560
<21,900
42,400
Manganese
7439-96-5
50
43
405
25.1
24.9
107
462
371
5,360
All values are in ng/L.
Notes
USEPA - United States Environmental Protection Agency
IMAC — Interim Maximum Allowable Concentration.
— Screening value not available
B - The associated numerical value was an estimated quantity below the reporting limit for an inorganic analyte.
D - Concentration obtained was the result of a dilution.
J - Detection is greater than the method detection limit but less than the limit of quantitation; value provided is estimated.
UJ - The analyte was not detected at a level greater than or equal to the quantitation limit. However, the quantitation limit is approximate and may be inaccurate or imprecise
Analyte Constituent identified as Constituent of Potential Concern in Human Health Risk Assessment.
1 - Risk based screening levels based on THQ= 1.0; non-cancer values have been divided by 10, as per EPA guidance
2 - Screening levels for endosulfan used. Endosulfan 02L includes a mixture of alpha and beta isomers.
3 - Screening levels for chlordane used.
4 - Screening levels for endrin used. NC15 02L levels include endrin, endrin aldehde, and endrin ketone.
The result exceeds the North Carolina Groundwater Quality Standards and IMACs.
The result exceeds the USEPA RSL for tapwater.
1/19/2015
Page 4 of 4
l:\Viacom-Triangle.l0679\47733.Revisions-To-Ri\Docs\Reports\RI\RI Report\Tables 11-2014\
Table 13 - Summary of Groundwater Analytical Results 2012.xlsx 11998
-------
Table 5-5b - Summary of Groundwater VOC Analytical Results 2017
Triangle Pacific
Elizabeth City, NC
North Carolina
USEPA Regional
MW-01
MW-01 D
MW-03
MW-03 D
MW-15
MW-15 D
MW-16
MW-16 D
DUPLICATE
Groundwater
Screening Level for
MW-01-091817
MW-01D-091917
MW-03-092117
MW-03D-092217
MW-15-091917
MW-15D-092017
MW-16-101117
MW-16D-101117
MW-18-101117
Quality Standards
Tapwater (June
9/18/2017
9/19/2017
9/21/2017
9/22/2017
9/19/2017
9/20/2017
10/11/2017
10/11/2017
10/11/2017
Analyte
Cas Number
and IMACs
2017)11]
1,2-Dichlorobenzene
95-50-1
20
30 121
14
62
11
1,3-Dichlorobenzene
541-73-1
200
-
2 J
1,4-Dichlorobenzene
106-46-7
6
0.48
2 J
5 J
cis-l,2-Dichloroethene
156-59-2
70
3.6 121
9
8
4
trans-l,2-Dichloroethene
156-60-5
100
36t2]
0.9 J
Trichloroethene
79-01-6
3
0.49
260
290
45
All units are in ng/L.
Notes:
USEPA United States Environmental Protection Agency
IMAC Interim Maximum Allowable Concentration
-- Screening value not available
J The detection is greater than the method detction limit, but less than the limit of quantitation; value provided is an estimate.
[1] Risk-based screening levels based on THQ=1.0. 0
[2] Non-cancer values have been divided by 10, as per USEPA guidance.
The result exceeds the North Carolina Groundwater Quality Standards and IMACs.
The result exceeds the USEPA Regional Screening Level for Tapwater.
The result exceeds both the North Carolina Groundwater Quality Standards and IMACs, as well as the USEPA Regional Screening Level for Tapwater.
Bold and Pink
Bold and Blue
Bold and Orange
OBG | THERE'S A WAY
PAGE 1 of 1
Table 4 - Summary of Groundwater Analytical Results.xlsx
-------
Background wells, upgradient of TCE plume
MW-01
MW-01D
Concentration
Concentration
Dissolved oxygen (mg/L)
0.67
0.68
Nitrate (mg/L)
2.8
<0.5
Iron (II) (mg/L)
0.065
14.5
Sulfate (mg/L)
26.6
13.9
Methane (mg/L)
<5
5
ORP(mV)
262.3
-22.5
pH (S.U.)
5.87
6.19
Carbon Dioxide (mg/L)111
44.3
54.7
Chloride (mg/L)[1]
8.3
13.1
Alkalinity (mg/L)111
55.6
137
BTEX (mg/L)
< 0.001
<0.001
TOC (mg/L)
1.8
1.6
Temperature (°C)
22.24
19.73
Hydrogen (nM)
2
2.1
Table 5-6 Natural Attenuation Screening
Triangle Pacific
Elizabeth City, NC
Wells within TCE plume
MW-03
MW-03D
MW-15
MW-15D
Concentration
Score
Concentration
Score
Concentration
Score
Concentration
Score
Dissolved oxygen (mg/L)
0.73
0
0.68
0
0.63
0
0.68
0
Nitrate (mg/L)
4.8
0
1
0
<0.5
2
<0.5
2
Iron (II) (mg/L)
0.057
0
0.019
0
0.97
0
0.095
0
Sulfate (mg/L)
30.9
0
5.1
2
34.2
0
63.7
0
Methane (mg/L)
10
3
20
3
3.2 J
3
69
3
ORP (mV)
420.7
0
281.6
0
49.5
1
130
0
pH (S.U.)
5.55
0
5.79
0
5.88
0
5.95
0
Carbon Dioxide (mg/L)111
80.8
0
60.2
0
56.3
0
81
0
Chloride (mg/L)111
26.4
2
22.6
0
11.8
0
28.2
2
Alkalinity (mg/L)I1]
64
0
47.7
0
89
0
128
0
BTEX (mg/L)
<0.001
0
<0.001
0
<0.001
0
<0.001
0
TOC (mg/L)
1.7
0
0.54 J
0
3.8
0
3.4
0
Temperature (°C)
20.24
1
18.13
0
20.22
1
18.35
0
Hydrogen (nM)
2.7
3
2.1
3
2
3
2
3
Total Score:
9
8
10
10 |
Wells downgradient of TCE plume
MW-16
MW-16D
MW-16D Duplicate
Concentration
Score
Concentration
Score
Concentration
Score
Dissolved oxygen (mg/L)
0.49
3
0.48
3
0.48
3
Nitrate (mg/L)
<0.5
0
<0.5
0
<0.5
0
Iron (II) (mg/L)
10.4
3
<0.05
0
0.022
0
Sulfate (mg/L)
34.5
0
10.7
2
11
2
Methane (mg/L)
20
3
46
3
42
3
ORP(mV)
21.3
1
145.4
0
145.4
0
pH (S.U.)
5.73
0
5.8
0
5.8
0
Carbon Dioxide (mg/L)111
285
1
109
0
72.5
0
Chloride (mg/L)111
9
0
15.5
0
15.1
0
Alkalinity (mg/L)111
113
1
68.7
0
72.3
0
BTEX (mg/L)
< 0.001
0
<0.001
0
< 0.001
0
TOC (mg/L)
5.1
0
0.61
0
0.63
0
Temperature (°C)
18.81
0
18.93
0
18.93
0
Hydrogen (nM)
2.1,2)
3
2.5
3
NM
0
Total Score:
15 1
1 11
8
Interpretation of Points Awarded During Screening Step
Score Interpretation
0 to 5
Inadequate evidence for anaerobic biodegradation (reductive dechlorination)
of chlorinated organics.
6 to 14
Limited evidence of anaerobic biodegradation (reductive dechlorination) of
chlorinated organics.
15 to 20
Adequate evidence for anaerobic biodegradation (reductive dechlorination) of
chlorinated organics.
>20
Strong evidence of anaerobic biodegradation (reductive dechlorination) of
chlorinated organics.
Table 2.4 from USEPA Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (1998)
Notes:
TOO Total organic carbon NM Not measured
BTEX Benzene, toluene, ethylbenzene, xylene S.U. Standard Units
1 - Detections at MW-01 and MW-01D used for background
values for shallow and deep wells, respectively.
2 - Hydrogen data is from September sampling event.
OBG I THERE'S A WAY
G
PAGE 1 of 1
Table 6 - Natural Attenuation Screening Rev2.xlsx
-------
RAGS TABLE 7-1a
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN ¦ EXPOSURE UNIT 1 (ACTIVE FACILITY AREA) ¦ SURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
IScenario: Current/Future
Medium: Soil
[Exposure Medium: Surface Soil (0-1 ft bgs)
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
(1)
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Industrial
Soil RSL
(4)
Screening
Toxicity Value
(5)
CO PC
Flag
(Y/Nj
Rationale for
Selection or
Deletion
(6)
Exposure Unit 1
METALS
Surface Soil
7429-90-5
Aluminum
3510 J
18800
mg/kg
BH-06
17/17
.
1.88E+04
NV
9.90E+04
n
9.90E+04
N
BSL
7440-36-0
Antimony
0,0911 J
1.54 J
mg/kg
BH-05
9/10
0.088-0.088
1.54E+00
NV
4.10E+01
n
4.10E+01
N
BSL
7440-38-2
Arsenic
2.22 J
13,2
mg/kg
F-SS-1
14/17
1.8-2.5
1.32E+01
NV
2.40E+00
c
2.40E+00
Y
ASL
7440-39-3
Barium
22.9 J
710 J
mg/kg
BH-05
17/17
-
7.10E+02
NV
1.90E+04
n
1.90E+04
N
BSL
7440-41-7
Beryllium
0.151 J
1.95 J
mg/kg
BH-05
14/17
0.18-0.25
1.95E+00
NV
2.00E+02
n
2.00E+02
N
BSL
7440-43-9
Cadmium
0.127 J
6.87 J
mg/kg
BH-05
12/17
0.0471-0.58
6.87E+00
NV
8.00E+01
n
8.00E+01
N
BSL
7440-70-2
Calcium
2200 J
66900
mg/kg
H-SS-1
10/17
1410-3020
6.69E+04
NV
NV
NV
N
NUT
7440-47-3
Chromium'
5,56 J
106 J
mg/kg
BH-21
24/24
-
1.06E+02
NV
1.50E+05
n
1.50E+05
N
BSL
7440-48-4
Cobalt
0.819 J
13 J
mg/kg
BH-01
17/17
-
1.30E+01
NV
3.00E+01
n
3.00E+01
N
BSL
7440-50-8
Copper
6,24 J
165 J
mg/kg
BH-03
17/17
.
1.65E+02
NV
4.10E+03
n
4.10E+03
N
BSL
57-12-5
Cyanide
0.21 B
1.7
mg/kg
A-SS-1
8/17
0.2-0.22
1.70E+00
NV
1.40E+01
n
1.40E+01
N
BSL
7439-89-8
Iron
5190 J
43800 J
mg/kg
BH-05
17/17
-
4.38E+04
NV
7.20E+04
n
7.20E+04
N
BSL
7439-92-1
Lead
5.03 J
604
mg/kg
BH-03
17/17
-
6.04E+02
NV
8.00E+02
n
8.00E+02
N
BSL
7439-95-4
Magnesium
954 J
2910 J
mg/kg
BH-05
17/17
-
2.91 E+03
NV
NV
NV
N
NUT
7439-96-5
Manganese
30.8
1220
mg/kg
BH-05
17/17
-
1.22E+03
NV
2.30 E+03
n
2.30E+03
N
BSL
7439-97-6
Mercury
0.0274 J
0.449
mg/kg
BH-05
15/17
0.0081-0.0083
4.49E-01
NV
4.30E+00
n
4.30E+00
N
BSL
7440-02-0
Nickel
2.82 J
28.8 J
mg/kg
BH-05
17/17
-
2.68E+01
NV
2,00 E+03
n
2.00E+03
N
BSL
7440-09-7
Potassium
216 U
2510 J
mg/kg
BH-05
17/17
-
2.51 E+03
NV
NV
NV
N
NUT
7782-49-2
Selenium
0.0914 J
3.08
mg/kg
BH-05
8/17
0.069-1.4
3.08E+00
NV
5.10E+02
n
5.10E+02
N
BSL
7440-22-4
Silver
0.0236 J
0.477 J
mg/kg
BH-05
10/17
0.0169-0.28
4.77E-01
NV
5.10E+02
n
5.10E+02
N
BSL
7440-23-5
Sodium
41.7 J
473 J
mg/kg
BH-05
9/17
34.8-374
4.73E+02
NV
NV
NV
N
NUT
7440-28-0
Thallium
0.0679 J
0.309 J
mg/kg
BH-05
8/17
0.0357-0.5
3.09E-01
NV
1.00E+00
n
1.00E+00
N
BSL
7440-62-2
Vanadium
8.71 J
28.6 J
mg/kg
BH-03
17/17
-
2.86E+01
NV
5.10E+02
n
5.10E+02
N
BSL
7440-06-6
Zinc
32.5 J
1110
mg/kg
BH-02
17/17
-
1,11 E+03
NV
3.10E+04
n
3.10E+04
N
BSL
PESTICIDES
72-54-8
4-4-DDD
0.003 J
0.047 JN
mg/kg
BH-05
6/17
0.00036-0.78
4.70E-02
NV
7.20E+00
c
7.20E+00
N
BSL
72-55-9
4-4-DDE
0.0026
0.55 J
mg/kg
BH-01
12/17
0.00036-0.048
5.50E-01
NV
5.10E+00
c
5.10E+00
N
BSL
50-29-3
4.4. DDT
0.002 J
2
mg/kg
BH-01
11/17
0.00036-0.048
2.00E+00
NV
7.00E+00
c
7.00E+00
N
BSL
309-00-2
Aldrin
0.016 J
0.11 J
mg/kg
BH-01
2/9
0.00019-0.022
1.10E-01
NV
1.00E-01
c
1.00E-01
Y
ASL
319-85-7
b-BHC
0.0021 J
0.013 J
mg/kg
A-SS-1
5/17
0.0011-0.13
1.30E-02
NV
9.60E-01
c
9.60E-01
N
BSL
12789-03-6
Constituents of Chlordane1"
0.0015
0.33
mg/kg
BH-01
7/16
0.00019-0.53
3.30E-01
NV
6.50E+00
c
6.50E+00
N
BSL
319-86-8
d-BHC'
0.0025 J
0.0025 J
mg/kg
A-SS-1
1/17
0.00049-0.059
2.50E-03
NV
9.60E-01
c
9.60E-01
N
BSL
60-57-1
Dieldrin
0.0043 JN
0.067 JN
mg/kg
BH-05
3/17
0,00038-0.13
6.70E-02
NV
1.10E-01
c
1.10E-01
N
BSL
959-98-8
Endosulfan 1
0.0013 JN
0.31 J
mg/kg
BH-05
3/17
0.00027-0.11
3.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
33213-65-9
Endosulfan IT'
0.00066 J
0.00066 J
mg/kg
BH-08
1/9
0.00036-0.044
6.60E-04
NV
3.70E+02
n
3.70E+02
N
BSL
1031-07-8
Endosulfan Sulfate'1
0,0087
0.41 J
mg/kg
BH-02
10/17
0.00038-0.048
4.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
72-20-8
Endrin
0.23 J
0.25
mg/kg
BH-03
2/17
0.00036-48
2.50E-01
NV
1.80E+01
n
1.80E+01
N
BSL
53494-70-5
Endrin Ketone"
0.86
0,86
mg/kg
BH-01
1/17
0.00066-48
8.60E-01
NV
1.80E+01
n
1.80E+01
N
BSL
76-44-8
Heptaehlor
0.0018
0.007 J
mg/kg
D-SS-1
3/17
0.00019-0.025
7.00E-03
NV
3.80E-01
c
3.80E-01
N
BSL
1024-57-3
Heptachlor Epoxide
0,00062 J
0.018 J
mg/kg
E-SS-1
5/17
0.0002-0.025
1.80E-02
NV
1.90E-01
c
1.90E-01
N
BSL
58-89-9
Lindane
0.00045 J
0.25 J
mg/kg
BH-02
6/9
0,0037-0.017
2.50E-01
NV
2.10E+00
c
2.10E+00
N
BSL
72-43-5
Methoxychlor
0.091 J
1,20
mg/kg
BH-05
2/9
0.0019-0.22
1.20E+00
NV
3.10E+02
n
3.10E+02
N
BSL
VOCs
71-55-8
1,1,1 -T richloroethane
0.004 J
0.13 D
mg/kg
D-SS-1
7/17
0.0009-0.013
1.30E-01
NV
3.80E+03
n
3.80E+03
N
BSL
78-87-5
1,2-Diohloropropane
0.016
0.016
mg/kg
B-SS-1
1/17
0.0009-0.015
1.60E-02
NV
4.70E+00
c
4.70E+00
N
BSL
67-64-1
Acetone
0.004 J
0.022 J
mg/kg
BH-08
2/17
0.006-0.022
2.20E-02
NV
6.30E+04
n
6.30E+04
N
BSL
75-09-2
Methylene Chloride
0.007 U
0.046
mg/kg
B-SS-1
6/17
0.002-0.013
4.60E-02
NV
9.60E+02
c
9.60E+02
N
BSL
127-18-4
Tetraehloroethene
0.004 J
0.12 D
mg/kg
D-SS-1
5/15
0,0009-0.013
1.20E-01
NV
1.10E+02
c
1.10E+02
N
BSL
108-88-3
Toluene
0.045 J
0.28 D
mg/kg
B-SS-1
6/15
0.0009-0.012
2.80E-01
NV
4.50E+03
n
4.5QE+03
N
BSL
79-01-6
Trichloroethylene
0.002 J
0.047 J
mg/kg
D-SS-1
3/17
0.0009-12
4.70E-02
NV
6.00E+00
c
6.00E+00
N
BSL
179601-23-1
Xylenes (m/p)
0.003 J
0.003 J
mg/kg
BH-08
1/7
0.0009-0.001
3.00E-03
NV
2.50E+02
n
2.50E+02
N
BSL
1330-20-7
Xylenes (Total)
0.003 J
0.003 J
mg/kg
BH-08
1/15
0.0009-0.015
3.00E-03
NV
2.70E+02
n
2.70E+02
N
BSL
i Tr,V. P-.t ,..f, T.. hi- 11 10 Ui, 1 1,1.1-1' 1 E1 '1 lyflj.- 1-mI l.f~~r, iii..j PlL . -I j 11
-------
RAGS TABLE 7.1a
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN ¦ EXPOSURE UNIT 1 (ACTIVE FACILITY AREA) ¦ SURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
IScenario: Current/Future
Medium: Soil
[Exposure Medium: Surface Soil (0-1 ft bgs)
Minimum
Maximum
Location of
Concentration
Potential
USEPA Industrial
Screening
COPC
Rationale for
Exposure Point
CAS Number
Chemical
Detected
Detected
Units
Detection
Range of
Used for
ARAR/TBC
Selection or
Concentration
(1)
Concentration
(1)
Maximum
Concentration
Frequency
Detection Limits
Screening
(2)
Value
(3)
Soil KoL
(4)
Toxicity Value
(5)
Flag
(Y/Nj
Deletion
(6)
SVOCs
92-52-4
1,1'-Biphenyl
0.08
0.9 J
mg/kg
BH-05
2/9
0.018-1.1
9.00E-01
NV
2.00E+01
n
2.00E+01
N
BSL
01-57-6
2-Methylnaphthalene
0.0039 J
4.1
mg/kg
BH-05
8/17
0.0041-4.8
4.10E+00
NV
2.20E+02
n
2.20E+02
N
BSL
106-44-5
4-Methylphenol
0.045
0.045
mg/kg
BH-08
1/9
0.018-1.1
4.50E-02
NV
6.20E+03
n
6.20E+03
N
BSL
83-32-8
Acenaphthene
0.013
5.9
mg/kg
BH-03
7/17
0.0037-4.8
5.90E+00
NV
3.30E+03
n
3.30E+03
N
BSL
208-96-8
Acenaphthylene
0.0025 J
0.25
mg/kg
BH-05
8/17
0.017-4.8
2.50E-01
NV
NV
NV
Y
NTX
120-12-7
Anthracene
0.0029 J
9.7
mg/kg
BH-03
11/17
0.38-4.8
9.70E+00
NV
1.70E+04
n
1.70E+04
N
BSL
56-55-3
Benz[a]anthracene
0.0058 J
20
mg/kg
BH-03
13/17
0.38-0.43
2.00E+01
NV
2.10E+00
c
2.10E+00
Y
ASL
50-32-8
Benzo[a]pyrene
0.03
19
mg/kg
BH-03
12/17
0.38-4.8
1.90E+01
NV
2.10E-01
c
2.10E-01
Y
ASL
205-09-2
Benzo[b]fluoranthene
0.052
31
mg/kg
BH-03
11/16
0.0041-4.8
3.10E+01
NV
2.10E+00
c
2.10E+00
Y
ASL
191-24-2
Benzo[g.h.i]perylene'
0.011
7.9 J
mg/kg
BH-02
11/17
0.0041-4.8
7.90E+00
NV
1.70E+03
n
1.70E+03
N
BSL
207-08-9
Benzo[k]fluoranthene
0.022
13
mg/kg
BH-03
11/17
0.0041-4.8
1.30E+01
NV
2.10E+01
c
2.10E+01
N
BSL
117-81-7
bis(2-Ethylhexyl)Phthalate
0.83
1500 DJ
mg/kg
BH-Q4
14/17
0.074-0.078
1.50E+03
NV
1.20E+02
c
1.20E+02
Y
ASL
85-68-7
Butylbenzylphthalate
0.29 J
8.2 D
mg/kg
E-SS-1
3/17
0.074-4.8
8.20E+00
NV
9.10E+02
c
9.10E+02
N
BSL
86-74-8
Carbazole
0.22 J
11
mg/kg
BH-05
5/17
0.018-4.8
1.10E+01
NV
NV
NV
Y
NTX
218-01-9
Chrysene
0.01 J
23
mg/kg
BH-03
12/17
0.38-4.8
2.30E+01
NV
2.10E+02
c
2.10E+02
N
BSL
53-70-3
Dibenz[a,h]anthracene
0.069
2.6 J
mg/kg
BH-02
6/13
0.0037-430
2.60E+00
NV
2.10E-01
c
2.10E-01
Y
ASL
132-64-9
Dibenzofuran
0.31
6.4
mg/kg
BH-05
4/17
0.018-4800
6.40E+00
NV
1.00E+02
n
1.00E+02
N
BSL
117-84-0
Di-n-octylphthalate
0.26 J
5.1 J
mg/kg
BH-05
5/15
0.074-4.8
5.10E+00
NV
6.20E+02
n
6.20E+02
N
BSL
206-44-0
Fluoranthene
0,014
61
mg/kg
BH-03
13/17
0.38-0.43
6.10E+01
NV
2.20E+03
n
2.20E+03
N
BSL
86-73-7
Fluorene
0.0054 J
5.2
mg/kg
BH-03
7/17
0.0037-4.8
5.20E+00
NV
2.20E+03
n
2.20E+03
N
BSL
193-39-5
lndeno[1,2,3-cd]pyrene
0.011
8.1 J
mg/kg
BH-02
11/17
0.0041-4.8
8.10E+00
NV
2.10E+00
c
2.10E+00
Y
ASL
91-20-3
Naphthalene
0.005 J
6.6
mg/kg
BH-03
9/17
0.0041-4.8
6.60E+00
NV
1.80E+01
c
1.80E+01
N
BSL
85-01-8
Phenanthrene'-1
0,012
48
mg/kg
BH-03
13/17
0.38-0.43
4.80E+01
NV
1.70E+04
n
1.70E+04
N
BSL
129-00-0
Pyrene
0.034
43
mg/kg
BH-03
13/17
0.38-0.43
4.30E+01
NV
1.70E+03
n
1.70E+03
N
BSL
PCBs
11097-69-1
Aroclor-1254
0.91
10 J
mg/kg
BH-Q1
6/17
0.0037-0.043
1.00E+01
NV
7.40E-01
c
7.40E-01
Y
ASL
11096-82-5
Aroclor-1260
0,025 J
3.7
ma/kg
BH-03
7/17
0.0037-0.33
3.70E+00
NV
7.40E-01
c
7.40E-01
Y
ASL
Definitions:
ARAR: Applicable or Relevant and Appropriate Requirements
CAS: Chemical Abstact Service
COPC: Chemical of Potential Concern
NUT: Chemical is an essential nutrient and is not screened in
RSL: Regional Screening Level: USEPA. 2014
TBC: To Be Considered
USEPA: United States Environmental Protection Agency
(6) Selection Rationale: ASL - Above Screening Level: NTX - No Toxicity Information. Deletion Rationale: BSL - Below Screening Level.
a = RSL value for chromium (III) applied: hexavalent chromium not detected in any site samples,
b = RSL value tor chiordane used,
c = RSL value for b-BHC used,
d = RSL value for endosulfen used,
e = RSL value for endrin used,
f = RSL value for pyre re used,
g = RSL for anthracene used.
= Chemical detected in 100% of samples.
Constituents of Chiordane includes all isomers detected.
Notes:
(1) J - estimated value: JN - presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions,
D - discrepancies between reported concentrations may be due to dilution of the sample or extract. B - constituent was also found in associated
method blank. U - reading was below method detection limit.
(2) Concentration used for screening is the maximum detected concentration.
(3) No ARAR values were considered for this exposure medium.
(4) USEPA Industrial Soil RSLs (May 2014): e = Cancer RSL; n = Noncancer RSL; NV = No value. Noncancer RSLs adjusted by multiplying RSL by 0.1.
(5) The Screening Toxicity Value represents the USEPA Industrial Soil RSLs table value.
i inv.P-.i ,..f, t.. ill*- 11 iuin»i 1 Em i-jfi*.- ;..,i r,p;l . j t,
-------
RAGS TABLE 7-1b
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 1 (ACTIVE FACILITY AREA! ¦ SURFACE AND SUBSURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
IScenario: Current/Future
Medium: Soil
[Exposure Medium: Surface and Subsurface Soil (0-10 ft bgs)
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
(1)
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Industrial
Soil RSL
(4)
Screening
Toxicity Value
(5)
CO PC
Flag
(Y/Nj
Rationale for
Selection or
Deletion
(6)
Exposure Unit 1
METALS
Surface and
7429-90-5
Aluminum
3070
42300 J
mg/kg
BH-02
39/39
.
4.23E+04
NV
9.90E+04
n
9.90E+04
N
BSL
Subsurface Soil
7440-36-0
Antimony
0,0911 J
1.54 J
mg/kg
BH-05
9/24
0,0817-1.3
1.54E+00
NV
4.10E+01
n
4.10E+01
N
BSL
7440-38-2
Arsenic
0.897 J
13,2
mg/kg
F-SS-1
27/39
0.98-2.5
1.32E+01
NV
2.40E+00
c
2.40E+00
Y
ASL
7440-39-3
Barium
9,81 J
710 J
mg/kg
BH-05
39/39
-
7.10E+02
NV
1.90E+04
n
1.90E+04
N
BSL
7440-41-7
Beryllium
0,0842 J
1.95 J
mg/kg
BH-05
34/39
0.09-0.25
1.95E+00
NV
2.00E+02
n
2.00E+02
N
BSL
7440-43-9
Cadmium
0,0573 J
6.87 J
mg/kg
BH-05
15/39
0.0471-0.58
6.87E+00
NV
8.00E+01
n
8.00E+01
N
BSL
7440-70-2
Calcium
149 J
66900
mg/kg
H-SS-1
22/39
393-3020
6.69E+04
NV
NV
NV
N
NUT
7440-47-3
Chromium'
4,78 J
106 J
mg/kg
BH-21
48/46
-
1.06E+02
NV
1.50E+05
n
1.50E+05
N
BSL
7440-48-4
Cobalt
0.318 J
13 J
mg/kg
BH-01
39/39
-
1.30E+01
NV
3.00E+01
n
3.00E+01
N
BSL
7440-50-8
Copper
1,14 J
165 J
mg/kg
BH-03
38/39
1.6-1.6
1.65E+02
NV
4.10E+03
n
4.10E+03
N
BSL
57-12-5
Cyanide
0.21 B
1.7
mg/kg
A-SS-1
9/39
0.19-0.3
1.70E+00
NV
1.40E+01
n
1.40E+01
N
BSL
7439-89-8
Iron
1840 J
43800 J
mg/kg
BH-05
39/39
-
4.38E+04
NV
7.20E+04
n
7.20E+04
N
BSL
7439-92-1
Lead
1.37 J
604
mg/kg
BH-03
39/39
-
6.04E+02
NV
8.00E+02
n
8.00E+02
N
BSL
7439-95-4
Magnesium
203 J
3740
mg/kg
BH-02
37/39
1200-1760
3.74E+03
NV
NV
NV
N
NUT
7439-96-5
Manganese
9.24
1220
mg/kg
BH-05
39/39
-
1.22E+03
NV
2.30 E+03
n
2.30E+03
N
BSL
7439-97-6
Mercury
0.0094 J
0.449
mg/kg
BH-05
33/39
0.0076-0.03
4.49E-01
NV
4.30E+00
n
4.30E+00
N
BSL
7440-02-0
Nickel
1.26 J
28.8 J
mg/kg
BH-05
39/39
-
2.68E+01
NV
2,00 E+03
n
2.00E+Q3
N
BSL
7440-09-7
Potassium
200 J
2510 J
mg/kg
BH-05
37/39
921-951
2,51 E+03
NV
NV
NV
N
NUT
7782-49-2
Selenium
0.0914 J
3.08
mg/kg
BH-05
19/39
0.0648-1.4
3.08E+00
NV
5.10E+02
n
5.10E+02
N
BSL
7440-22-4
Silver
0.0163 J
0.477 J
mg/kg
BH-05
24/39
0.0169-0.29
4.77E-01
NV
5.10E+02
n
5.10E+02
N
BSL
7440-23-5
Sodium
41.7 J
697 J
mg/kg
BH-05
21/39
11.2-374
6.97E+02
NV
NV
NV
N
NUT
7440-28-0
Thallium
0.0679 J
0.309 J
mg/kg
BH-05
19/39
0.0335-0.5
3.09E-01
NV
1.00E+00
n
1.00E+00
N
BSL
7440-62-2
Vanadium
4,44 J
52.6 J
mg/kg
BH-02
39/39
-
5.26E+01
NV
5.10E+02
n
5.10E+02
N
BSL
7440-06-6
Zinc
2,74 J
1110
mg/kg
BH-02
37/39
4.2-10.6
1,11 E+03
NV
3.10E+04
n
3.10E+04
N
BSL
PESTICIDES
72-54-8
4-4-DDD
0.003 J
0.047 JN
mg/kg
BH-05
6/37
0.00036-0.78
4.70E-02
NV
7.20E+00
c
7.20E+00
N
BSL
72-55-9
4-4-DDE
0.0018 J
0.55 J
mg/kg
BH-01
17/37
0.00036-0.048
5.50E-01
NV
5.10E+00
c
5.10E+00
N
BSL
50-29-3
4.4. DDT
0.002 J
2
mg/kg
BH-01
16/37
0.00036-0.048
2.00E+00
NV
7.00E+00
c
7.00E+00
N
BSL
309-00-2
Aldriri
0.0015 JN
0.11 J
mg/kg
BH-01
3/21
0.00019-0.022
1.10E-01
NV
1.00E-01
c
1.00E-01
Y
ASL
319-85-7
b-BHC
0.0021 J
0.013 J
mg/kg
A-SS-1
5/37
0.0011-0.13
1.30E-02
NV
9.60E-01
c
9.60E-01
N
BSL
12789-03-6
Constituents of Chlordane1"
0.0013
0.3371
mg/kg
BH-01
11/25
0.0036-0.662
3.37E-01
NV
6.50E+00
c
6.50E+00
N
BSL
319-86-8
d-BHC'
0.0025 J
0.0025 J
mg/kg
A-SS-1
1/37
0.00049-0.059
2.50E-03
NV
9.60E-01
c
9.60E-01
N
BSL
60-57-1
Dieldrin
0.001 J
0.067 JN
mg/kg
BH-05
5/37
0,00038-0.13
6.70E-02
NV
1.10E-01
c
1.10E-01
N
BSL
959-98-8
Endosulfan 1
0.00081 J
0.31 J
mg/kg
BH-05
4/37
0.00025-0.11
3.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
33213-65-9
Endosulfan IT'
0.00064 J
0.00066 J
mg/kg
BH-08
2/21
0.00036-0.044
6.60E-04
NV
3.70E+02
n
3.70E+02
N
BSL
1031-07-8
Endosulfan Sulfate'1
0.00053 J
0.41 J
mg/kg
BH-02
13/37
0.00038-0.048
4.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
72-20-8
Endrin
0.0013 J
0.25
mg/kg
BH-03
3/37
0.00036-48
2.50E-01
NV
1.80E+01
n
1.80E+01
N
BSL
53494-70-5
Endrin Ketone"
0.00094 J
0,86
mg/kg
BH-01
3/37
0.00066-48
8.60E-01
NV
1.80E+01
n
1.80E+01
N
BSL
76-44-8
Heptachlor
0.0018
0.007 J
mg/kg
D-SS-1
3/37
0.00019-0.025
7.00E-03
NV
3.80E-01
c
3.80E-01
N
BSL
1024-57-3
Heptachlor Epoxide
0.00041 J
0.018 J
mg/kg
E-SS-1
6/37
0.00019-0.025
1.80E-02
NV
1.90E-01
c
1.90E-01
N
BSL
58-89-9
Lindane
0.00045 J
0.25 J
mg/kg
BH-02
10/21
0.00019-0.017
2.50E-01
NV
2.10E+00
c
2.10E+00
N
BSL
72-43-5
Methoxychlor
0.091 J
1.2
mg/kg
BH-05
2/21
0.0019-0.22
1.20E+00
NV
3.10E+02
n
3.10E+02
N
BSL
VOCs
71-55-8
1,1.1 -T riehloroethane
0.004 J
0.13 D
mg/kg
D-SS-1
11/39
0.0009-0.014
1.30E-01
NV
3.80E+03
n
3.80E+03
N
BSL
78-87-5
1,2-Dichloropropane
0.016
0.016
mg/kg
B-SS-1
1/39
0.0009-0.015
1.60E-02
NV
4.70E+00
c
4.70E+00
N
BSL
78-93-3
2-Butanone
0.005 J
0.016
mg/kg
BH-05
2/39
0.004-0.015
1.60E-02
NV
2.00E+04
n
2.00E+04
N
BSL
67-64-1
Acetone
0.004 J
0.075
mg/kg
BH-05
6/39
0.006-0.022
7.50E-02
NV
6.30E+04
n
6.30E+04
N
BSL
75-25-2
Bromoform
0.003 DJ
0.003 DJ
mg/kg
D-SS-2
1/37
0,0009-0.015
3.00E-03
NV
2.20E+02
c
2.20E+02
N
BSL
75-09-2
Methylene Chloride
0.003 J
0.046
mg/kg
B-SS-1
13/39
0.001-0,014
4.60E-02
NV
9.60E+02
c
9.6QE+02
N
BSL
127-18-4
T etrachloroethene
0.002 J
0.12 D
mg/kg
D-SS-1
13/37
0.0009-0.013
1.20E-01
NV
1.10E+02
c
1.10E+02
N
BSL
108-88-3
Toluene
0.021 J
0.51 D
mg/kg
A-SS-2
14/37
0.0009-0.014
5.10E-01
NV
4.50E+03
n
4.50E+03
N
BSL
79-01-6
Trichloroethylene
0.002 J
0.047 J
mg/kg
D-SS-1
6/39
0.0009-12
4.70E-02
NV
6.00E+00
c
6.00E+00
N
BSL
179601-23-1
Xylenes (m/p)
0.003 J
0.003 J
mg/kg
BH-08
1/19
0.0009-0.001
3.00E-03
NV
2.50E+02
n
2.50E+02
N
BSL
1330-20-7
Xylenes (Total)
0.003 J
0.003 J
mg/kg
BH-08
1/37
0,0009-0.015
3.00E-03
NV
2.70E+02
n
2.70E+02
N
BSL
I i«. ..(i> Tinii.)!- 1 J""" V- P— i »•(. HHP" hl« n 10 1J-L. I T P-<-1 T «W- j J E"1 lull Iyt -Hi !•"! I• f--ii «l
v"E< l-l'i *
-------
RAGS TABLE 7-1b
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 1 (ACTIVE FACILITY AREA! ¦ SURFACE AND SUBSURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
IScenario: Current/Future
Medium: Soil
[Exposure Medium: Surface and Subsurface Soil (0-10 ft bgs)
Minimum
Maximum
Location of
Concentration
Potential
USEPA Industrial
Screening
COPC
Rationale for
Exposure Point
CAS Number
Chemical
Detected
Detected
Units
Detection
Range of
Used for
ARAR/TBC
Selection or
Concentration
(1)
Concentration
(1)
Maximum
Concentration
Frequency
Detection Limits
Screening
(2)
Value
(3)
Soil KoL
(4)
Toxicity Value
(5)
Flag
(Y/Nj
Deletion
(6)
Exposure Unit 1
SVOCs
Surface and
92-52-4
1.1'-Biphenyl
0.08
0.9 J
mg/kg
BH-05
3/21
0.018-1.1
9.00E-01
NV
2.00E+01
n
2.00E+01
N
BSL
Subsurface Soil
01-57-6
2-Methyl naphthalene
0.00092 J
4.1
mg/kg
BH-05
15/39
0.00077-4,8
4.10E+00
NV
2.20E+02
n
2.20E+02
N
BSL
106-44-5
4-Methylphenol
0.045
0.045
mg/kg
BH-08
1/21
0,018-1,1
4.50E-02
NV
6.20E+03
n
6.20E+03
N
BSL
83-32-8
Acenaphthene
0.001 J
5.9
mg/kg
BH-03
14/39
0.00077-4.8
5.90E+00
NV
3.30E+03
n
3.30E+03
N
BSL
208-96-8
Acenaphthylene
0.00058 J
0,3 J
mg/kg
T-SS-1
13/39
0.00038-4.8
3.00E-01
NV
NV
NV
Y
NTX
120-12-7
Anthracene
0.00065 J
9.7
mg/kg
BH-03
22/39
0.00038-4.8
9.70E+00
NV
1.70E+04
n
1.70E+04
N
BSL
56-55-3
Benz[a]anthracene
0.0016 J
20
mg/kg
BH-05
24/39
0.00077-4
2.00E+01
NV
2.10E+00
c
2.10E+00
Y
ASL
50-32-8
Benzo[a]pyrene
0.0016 J
19
mg/kg
BH-03
22/39
0.00077-4.8
1.90E+01
NV
2.10E-01
c
2.10E-01
Y
ASL
205-09-2
Benzo[b]fluoranthene
0.0031
31
mg/kg
BH-03
22/38
0.00077-4.8
3.10E+01
NV
2.10E+00
c
2.10E+00
Y
ASL
191-24-2
Benzo[g,h.i]perylene'
0.0012 J
7.9 J
mg/kg
BH-02
21/39
0.00077-4.8
7.90E+00
NV
1.70E+03
n
1.70E+03
N
BSL
207-08-9
Benzo[k]fluoranthene
0.0015 J
13
mg/kg
BH-05
22/39
0.00077-4,8
1.30E+01
NV
2.10E+01
c
2.10E+01
N
BSL
117-81-7
bis(2-Ethylhexyl)Phthalate
0,21 J
1500
mg/kg
BH-04
26/39
0.074-0.44
1.50E+03
NV
1.20E+02
c
1.20E+02
Y
ASL
85-68-7
Butylbenzylphthalate
0,29 J
8.2 D
mg/kg
E-SS-1
3/39
0,074-4,8
8.20E+00
NV
9.10E+02
c
9.10E+02
N
BSL
86-74-8
Carbazole
0.036 J
11
mg/kg
BH-05
9/39
0.018-4.8
1.10E+01
NV
NV
NV
Y
NTX
218-01-9
Chrysene
0.0016 J
23
mg/kg
BH-03, BH-05
23/39
0.00038-4,8
2.30E+01
NV
2.10E+02
c
2.10E+02
N
BSL
53-70-3
Dibenz[a,h]anthracene
0.00089 J
2.6 J
mg/kg
BH-02
15/34
0.00077-4000
2.60E+00
NV
2.10E-01
c
2.10E-01
Y
ASL
132-64-9
Di&enzofuran
0.041
6.4
mg/kg
BH-05
7/39
0.018-4800
6.40E+00
NV
1.00E+02
n
1.00E+02
N
BSL
117-84-0
Di-n-octylphthalate
0,26 J
6.8
mg/kg
A-SS-2
6/37
0,074-4,8
6.80E+00
NV
6.20E+02
n
6.20E+02
N
BSL
206-44-0
Fluoranthene
0,0032
61
mg/kg
BH-03
24/39
0.00077-4
6.10E+01
NV
2.20E+03
n
2.20E+03
N
BSL
86-73-7
Fluorene
0.0019 J
5.2
mg/kg
BH-03
13/39
0.00077-4.8
5.20E+00
NV
2.20E+03
n
2.20E+03
N
BSL
193-39-5
lndeno[1,2,3-cd]pyrene
0.00098 J
8.1 J
mg/kg
BH-02
21/39
0.00077-4,8
8.10E+00
NV
2.10E+00
c
2.10E+00
Y
ASL
91-20-3
Naphthalene
0.00087 J
6.6
mg/kg
BH-03
18/39
0.00077-4,8
6.60E+00
NV
1.80E+01
c
1.80E+01
N
BSL
85-01-8
Phenanthrene'-1
0,0017 J
48
mg/kg
BH-03
24/39
0.00077-4
4.80E+01
NV
1.70E+04
n
1.70E+04
N
BSL
129-00-0
Pyrene
0,0026
43
mg/kg
BH-03
25/39
0,00077-0.43
4.30E+01
NV
1.70E+03
n
1.70E+03
N
BSL
PCBs
11097-69-1
Aroclor-1254
0.01 J
10 J
mg/kg
BH-Q1
16/37
0.0037-0.041
1.00E+01
NV
7.40E-01
c
7.40E-01
Y
ASL
11096-82-5
Arodor-1260
0,0063 J
3.7
ma/kg
BH-03
12/37
0.0037-0.041
3.70E+00
NV
7.40E-01
c
7.40E-01
Y
ASL
Definitions:
ARAR: Applicable or Relevant and Appropriate Requirements
CAS: Chemical Abstact Service
COPC: Chemical of Potential Concern
NUT: Chemical is an essential nutrient and is not screened in
RSL: Regional Screening Level: USEPA. 2014
TBC: To Be Considered
USEPA: United States Environmental Protection Agency
a = RSL value for chromium (III) applied; hexavalent chromium not detected in any site samples,
b = RSL value for chlordane used,
c = RSL value for b-BHC used,
d = RSL value for endosulfan used,
e = RSL value for endrin used,
f = RSL value for pyrene used,
g = RSL value for anthracene used.
= Chemical detected in 100% of samples.
Constituents of Chlordane includes all isomers detected.
Notes:
(1) J - estimated value: JN - presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions. D - discrepancies
between reported concentrations may be due to dilution of the sample or extract. B - constituent was also found in associated method blank.
(2) Concentration used for screening is the maximum detected concentration.
(3) No ARAR values were considered for this exposure medium.
(4) USEPA Industrial Soil RSLs (May 2014): e = Cancer RSL: n = Noncaneer RSL; NV = No value. N on cancer RSLs adjusted by multiplying RSL by 0.1.
(5s The Screening Toxicity Value represents the USEPA Industrial Soil RSLs table value.
(8) Selection Rationale; ASL - Above Screening Level: NTX - No Toxicity Information, Deletion Rationale; BSL-Below Screwing Level.
I i«. ..(i> Tinii.)!- 1 J""" V- F-'— i »•(. HHP- ltl~ 11 ly 14-L, | WkljI-T ,[•!« P-i]-1 T j J E"! lull lyt> -Hi !•"! *1 -
v"E< l-l'i *
-------
RAGS TABLE 7-1c
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 1 (ACTIVE FACILITY AREA) - SHALLOW GROUNDWATER
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NORTH CAROLINA
Scenario: Current/Future
Medium: Water
Exposure Medium: Groundwater
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
(1)
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Tapwater
RSL
(4)
Screening
Toxicity Value
(5)
COPC
Flag
(Y/N)
Rationale for
Selection or
Deletion
(6)
Exposure Unit 1
METALS
Shallow
7429-90-5
Aluminum
49.9 J
435
ug/L
MW-15
7/8
6.5-6.5
4.35E+02
NV
1.60E+03
n
1.60E+03
N
BSL
Groundwater
7440-36-0
Antimony
0.54 J
1.1 J
ug/L
MW-4
2/8
0.33-0.42
1.10E+00
NV
6.00E-01
n
6.00E-01
Y
ASL
7440-38-2
Arsenic
0.58
37.4 J
ug/L
MW-14
6/9
0.4-0.95
3.74E+01
NV
4.50E-02
c
4.50E-02
Y
ASL
7440-38-3
Barium
10.6 J
113 J
ug/L
MW-14
8/8
-
1.13E+02
NV
2 90E+02
n
2.90E+02
N
BSL
7440-43-9
Cadmium
0.094 J
0,51 J
ug/L
MW-1
2/8
0.082-0.2
5.10E-01
NV
6.90E-01
n
6.90E-01
N
BSL
7440-70-2
Calcium
15900 J
89600 J
ug/L
MW-14
8/8
.
8.96E+04
NV
NV
NV
N
NUT
7440-47-3
Chromium'
0.51
0.67 J
ug/L
MW-15
4/8
0.5-0.6
6.70E-01
NV
1.60E+03
n
1.60E+03
N
BSL
7440-46-4
Cobalt
1.2 J
12.5
ug/L
MW-16
4/8
0.62-0.66
1.25E+01
NV
4.70E-01
n
4.70E-01
Y
ASL
7440-50-8
Copper
0.59 J
6.7
ug/L
MW-1
6/8
0.38-0.4
8.70E+00
NV
8.20E+01
n
6.20E+01
N
BSL
7439-89-8
Iron
12.1 J
16200 J
ug/L
MW-14
8/8
-
1.62E+04
NV
1.10E+03
n
1.10E+03
Y
ASL
7439-92-1
Lead
0.15 J
0.8 J
ug/L
MW-2
7/8
0.034-0.034
8.00E-01
1.50E+01
NV
1.50E+01
N
BSL
7439-95-4
Magnesium
2900 J
21800
ug/L
MW-13
8/8
-
2.18E+04
NV
NV
NV
N
NUT
7439-96-5
Manganese
2 J
1970
ug/L
MW-16
8/8
.
1.97E+03
NV
3.20E+01
n
3.20E+01
Y
ASL
7439-97-8
Mercury
0.038 J
0.09 J
ug/L
MW-3
2/8
0.026-0.16
9.00E-02
NV
6.30E-02
n
8.30E-02
Y
ASL
7440-02-0
Nickel
0.75 J
2.3
ug/L
MW-16
7/8
0.5-0.5
2.30E+00
NV
3.00E+01
n
3.00E+01
N
BSL
7440-09-7
Potassium
1430
9690 J
ug/L
MW-14
8/8
-
9.69E+03
NV
NV
NV
N
NUT
7782-49-2
Selenium
0.36 J
1.8 J
ug/L
MW-1
5/8
0.27-0.5
1.80E+00
NV
7.80E+00
n
7.80E+00
N
BSL
7440-23-5
Sodium
4430 J
40100
ug/L
MW-13
8/8
-
4.01 E+04
NV
NV
NV
N
NUT
7440-62-2
Vanadium
0.87 J
3.3
ug/L
MW-1
8/8
.
3.30E+00
NV
6.30E+00
n
6.30E+00
N
BSL
7440-66-6
Zinc
3.7 J
12.7
ug/L
MW-16
8/8
-
1.27E+01
NV
4.70E+02
n
4.70E+02
N
BSL
PESTICIDES
12789-03-6
Constituents of Chlordane1'
2.96
2.96
ug/L
MW-2
1/3
0.0019-0.15
2.96E+00
NV
1.90E-01
c
1.90E-01
Y
ASL
60-57-1
Dieldrin
0.011 J
0.011 J
ug/L
MW-2
1/3
0.0051-0.0051
1.10E-02
NV
1.50E-03
c
1.50E-03
Y
ASL
959-98-8
Endosulfan 1
0.057
0.057
ug/L
MW-2
1/3
0.0041-0.0041
5.70E-02
NV
7.80E+00
n
7.80E+00
N
BSL
VOCs
95-50-1
1.2-Dichlorobenzene
38
38
ug/L
MW-3
1/8
0.7-0.7
3.80E+01
NV
2.80E+01
n
2.80E+01
Y
ASL
541-73-1
1,3-Dichlorobenzene'
1
1
ug/L
MW-16
1/8
1-1
1.00E+00
NV
4.20E-01
c
4.20E-01
Y
ASL
106-46-7
1,4-Dichiorobenzene
3 J
3 J
ug/L
MW-3
1/8
1-1
3.00E+00
NV
4.20E-01
c
4.20E-01
Y
ASL
67-64-1
Acetone
7 J
7 J
ug/L
MW-15
1/8
6-6
7.00E+00
NV
1.20E+03
n
1.20E+03
N
BSL
156-59-2
cis-1,2-Dichloroethylene
3 J
3 J
ug/L
MW-3
1/8
0.8-0.8
3.00E+00
NV
2.80E+Q0
n
2.80E+00
Y
ASL
79-01-6
Trichloroethylene
110
110
ug/L
MW-3
1/8
1-1
1.10E+02
NV
4.90E-01
c
4.90E-01
Y
ASL
SVOCs
91-57-6
2-Methylnaphthalene
0.015 J
0.015 J
ug/L
MW-14
1/3
0.0096-0.0096
2.10E-02
NV
2.70E+00
n
2.70E+00
N
BSL
106-44-5
4-Methylphenol
1
1
ug/L
MW-15
1/8
0.5-0.5
1.00E+00
NV
1.40E+02
n
1.40E+02
N
BSL
83-32-9
Acenaphthene
0.33
0.33
ug/L
MW-14
1/3
0.0096-0.0098
3.50E-01
NV
4.00E+01
n
4.00E+01
N
BSL
120-12-7
Anthracene
0.088
0.088
ug/L
MW-14
1/3
0.0096-0.0096
1.60E-01
NV
1.30E+02
n
1.30E+02
N
BSL
206-44-0
Fluoranthene
0.082
0.082
ug/L
MW-14
1/3
0.0096-0.0098
8.20E-02
NV
6.30E+01
n
6.30E+01
N
BSL
86-73-7
Fluorene
0.15
0.15
ug/L
MW-14
1/3
0.0096-0.0096
2.10E-01
NV
2.20E+01
n
2.20E+01
N
BSL
91-20-3
Naphthalene
0.038 J
0.11
ug/L
MW-2
3/3
.
1.10E-01
NV
1.40E-01
c
1.40E-01
N
BSL
85-01-8
Phenanthrene'1
0.27
0.27
ug/L
MW-14
1/3
0.029-0.029
2.70E-01
NV
1.30E+02
n
1.30E+02
N
BSL
129-00-0
Pyrene
0.053
0.053
ug/L
MW-14
1/3
0.0096-0.0096
5.30E-02
NV
8.70E+00
n
8.70E+00
N
BSL
PCBs
12672-29-6
Aroelor-1248
0.39 J
0.39 J
ug/L
MW-2
1/3
0.095-0.096
! 3.90E-01
NV
3.40E-02
c
3.40E-02
Y
ASL
Notes:
(1) J - estimated value.
(2) Concentration used for screening is the maximum detected concentration.
S3) The ARAR value utilized for lead is the MCL value {USEPA, May 2009).
(4) USEPATapwater RSLs (May 2014): c = Cancer RSL: n = Noncancer RSL: NV = No value. Noncancer RSLs
(5) The Screening Toxicity Value represents the USEPA Tapvtater RSL table value or MCL (lead).
(8) Selection Rationale: ASL - Above Screening Level: NTX - No Toxicity Information. Deletion Rationale: BSL
a = RSL value for chromium (III) applied: hexavalent chromium not detected in any site samples,
b = RSL value for chlordane used,
o = RSL value for 1.4-dichlorobenzene used,
d = RSL value for anthracene used.
adjusted by multiplying RSL
- Below Screening Level.
by 0.1.
Definitions:
ARAR: Applicable or Relevant and Appropriate Requirements
CAS: Chemical Abstact Service
COPC: Chemical of Potential Concern
NUT: Chemical is an essential nutrient and is not screened in
RSL: Regional Screening Level: USEPA, 2014
TBC: To Be Considered
USEPA: United States Environmental Protection Agency
= Chemical detected in 100% of samples.
Constituents of Chlordane includes all isomers detected.
,, t,, p.-, fv(s„,i hhp— - 11 id u l , i Hdiji-1 p- E"i j ;•
F j.J- ] I
-------
RAGS TABLE 7-1d
OCCURRENCE. DISTRIBUTION. AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 2 (SITEWIDE) - SURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
Scenario: Current/Future
Medium: Soil
Exposure Medium: Surface Soil jO-1 ft bgs)
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
(1)
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Industrial
Soil RSL
(4)
Screening
Toxicity Value
(5)
COPC
Flag
(Y/N)
Rationale for
Selection or
Deletion
m
Exposure Unit 2
METALS
Surface Soil
7429-90-5
Aluminum
3510 J
28200
mg/kg
BH-14
32/32
-
2.82E+04
NV
9.90E+04
n
9.90E+04
N
BSL
7440-36-0
Antimony
0.0854 J-
14,5 J
mg/kg
BH-18
22/25
0.0791-0.111
1.45E+01
NV
4.10E+01
n
4.10E+01
N
BSL
7440-38-2
Arsenic
1.96
127 J
mg/kg
BH-18
29/32
1.8-2.5
1.27E+02
NV
2.40E+00
c
2.40E+00
Y
ASL
7440-39-3
Barium
34.7
710 J
mg/kg
BH-05
32/32
-
7.10E+02
NV
1.90E+04
n
1.90E+04
N
BSL
7440-41-7
Beryllium
0.272 J
1.95 J
mg/kg
BH-05
29/32
0.18-0.25
1.95E+00
NV
2.00E+02
n
2.00E+02
N
BSL
7440-43-9
Cadmium
0.0247 J
60.6 J
mg/kg
BH-18
25/32
0.0471-0.58
6.06E+01
NV
8.00E+01
n
8.00E+01
N
BSL
7440-70-2
Calcium
486
66900
mg/kg
H-SS-1
25/32
1410-3020
6.69E+04
NV
NV
NV
N
NUT
7440-47-3
Chromium *
6.18
250 J
mg/kg
BH-18
38/38
-
2.50E+02
NV
1.50E+05
n
1.50E+05
N
BSL
7440-48-4
Cobalt
1.51
13 J
mg/kg
BH-01
32/32
-
1.30E+01
NV
3.00E+01
n
3.00E+01
N
BSL
7440-50-8
Copper
4.69
649
mg/kg
BH-18
32/32
.
6.49E+02
NV
4.10E+03
n
4.10E+03
N
BSL
57-12-5
Cyanide
0.21 B
1.7
mg/kg
A-SS-1
13/28
0.2-0.25
1.70E+00
NV
1.40E+01
n
1.40E+01
N
BSL
7439-89-6
I rem
5250
357000
mg/kg
BH-18
32/32
-
3.57E+05
NV
7.20E+04
n
7.20E+04
Y
ASL
7439-92-1
Lead
8.25
685
mg/kg
BH-18
32/32
-
6.85E+02
NV
8.00E+02
n
8.00E+02
N
BSL
7439-95-4
Magnesium
1010 B
3550
mg/kg
BH-26
32/32
-
3.55E+03
NV
NV
NV
N
NUT
7439-96-5
Manganese
59.1
1220
mg/kg
BH-05
32/32
-
1.22E+03
NV
2.30E+03
n
2.30E+03
N
BSL
7439-97-6
Mercury
0.0274 J
0.449
mg/kg
BH-05
31/32
0,0083-0.0083
4.49E-01
NV
4.30E+Q0
n
4.30E+00
N
BSL
7440-02-0
Nickel
3 B
182 J
mg/kg
BH-18
32/32
-
1.82E+02
NV
2.00E+03
n
2.00E+03
N
BSL
7440-09-7
Potassium
216
2510 J
mg/kg
BH-05
28/28
-
2.51E+03
NV
NV
NV
N
NUT
7782-49-2
Selenium
0.0914 J
3.08
mg/kg
BH-05
24/32
0.32-1.4
3.08E+00
NV
5.10E+02
n
5.10E+02
N
BSL
7440-22-4
Silver
0.0223 J
2.92 J
mg/kg
BH-18
24/32
0,0234-0.28
2.92E+00
NV
5.10E+02
n
5.10E+02
N
BSL
7440-23-5
Sodium
37.7 J
2860
mg/kg
BH-18
23/32
12.4-374
2 86E+03
NV
NV
NV
N
NUT
7440-28-0
Thallium
0.0679 J
0.309 J
mg/kg
BH-05
23/32
0.0875-0.5
3.09E-01
NV
1.00E+00
n
1.00E+00
N
BSL
7440-62-2
Vanadium
8.9 B
40.6 J
mg/kg
BH-14
32132
-
4.06E+01
NV
5.10E+02
n
5.10E+02
N
BSL
7440-66-6
Zinc
27.2 J
3570
mg/kg
BH-18
32/32
-
3.57E+03
NV
3.10E+04
n
3.10E+04
N
BSL
PESTICIDES
72-54-8
4-4-DDD
0.0014 J
0.14 J
mg/kg
BH-26
15/32
0.00036-0.78
1.40E-01
NV
7.20E+00
c
7.20E+00
N
BSL
72-55-0
4-4-DDE
0.0024 JN
2.6
mg/kg
BH-26
27/32
0.00036-0.048
2.60E+00
NV
5.10E+00
c
5.10E+00
N
BSL
50-29-3
4-4-DDT
0.0019 J
5.5
mg/kg
BH-18
22/32
0.00036-0.093
5.50E+00
NV
7.00E+00
c
7.00E+00
N
BSL
319-84-6
a-BHC
0.019 JN
0.13
mg/kg
BH-18
2/24
0.00019-0.022
1.30E-01
NV
2.70E-01
c
2.70E-01
N
BSL
309-00-2
Aldrin
0.00036 J
0.49 JN
mg/kg
BH-18
6/24
0.00019-0.034
4.90E-01
NV
1.00E-01
c
1.00E-01
Y
ASL
319-85-7
b-BHC
0.0045
0.013 J
mg/kg
A-SS-1
4/32
0.0011-0.13
1.30E-02
NV
9.60E-01
c
9.60E-01
N
BSL
12789-03-6
Constituents of Chlordane1'
0.00068
1.2
mg/kg
BH-18
18/32
0.00019-0.53
1.20E+00
NV
6.50E+00
c
6.50E+00
N
BSL
319-86-8
d-BHC'
0.0025 J
0.049
mg/kg
BH-18
3/32
0.00049-0.059
4.90E-02
NV
9.60E-01
c
9.60E-01
N
BSL
60-57-1
Dieidrin
0.0019 J
0.067 JN
mg/kg
BH-05
3/32
0.00036-0.31
6.70E-02
NV
1.10E-01
c
1.10E-01
N
BSL
959-98-8
Endosulfan I'1
0.0013 JN
0.31 J
mg/kg
BH-05
4/32
0.00025-0.11
3.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
33213-65-9
Endosulfan IT1
0,00078 J
0.00089 J
mg/kg
BH-24
2/24
0,00036-0.044
8.90E-04
NV
3.70E+02
n
3.70E+02
N
BSL
1031-07-8
Endosulfan Sulfate"1
0.0012 J
0.41 J
mg/kg
BH-02
13/32
0.00038-0.28
4.10E-01
NV
3.70E+02
n
3.70E+02
N
BSL
72-20-8
Endrin
0.0024
0.25
mg/kg
BH-03
5/32
0.00036-48
2.50E-01
NV
1.80E+01
n
1.80E+01
N
BSL
7421-93-4
Endrin Aldehyde'
0.0015 J
0.47
mg/kg
BH-18
5/32
0.00036-48
4.70E-01
NV
1.80E+01
n
1.80E+01
N
BSL
53494-70-5
Endrin Ketone"
0.86
0.86
mg/kg
BH-01
1/32
0.00066-48
8.60E-01
NV
1.80E+01
n
1.80E+01
N
BSL
76-44-8
Heptachlor
0.00052 J
0.01 J
mg/kg
BH-26
7/32
0.00019-0.025
1.00E-02
NV
3.80E-01
c
3.80E-01
N
BSL
1024-57-3
Heptachlor Epoxide
0.00062 J
0.018 J
mg/kg
E-SS-1
5/32
0.00019-0.061
1.80E-02
NV
1.90E-01
c
1.90E-01
N
BSL
58-89-9
Lindane
0.00042 J
0.25 J
mg/kg
BH-02
7/24
0.0002-0.017
2.50E-01
NV
2.1GE+00
c
2.10E+00
N
BSL
72-43-5
Methoxychlor
0.0046 J
1.2
mq/kq
BH-05
3/24
0.0019-0.22
1.20E+00
NV
3.10E+02
n
3.10E+02
N
BSL
Exposure Unit 2
VOCs
Surface Soil
71-55-6
1.1,1-Trichloroethane
0,004 J
0.13 D
mg/kg
D-SS-1
7/28
0.0009-0.013
1.30E-01
NV
3.80E+03
n
3.80E+03
N
BSL
78-87-5
1,2-Dichloropropane
0.016
0.016
mg/kg
B-SS-1
1/28
0.0009-0.015
1.60E-02
NV
4.70E+00
c
4.70E+00
N
BSL
67-64-1
Acetone
0,004 J
0.38
mg/kg
BH-20
8/28
0.006-0.033
3.80E-01
NV
6.30E+04
n
6.30E+04
N
BSL
98-86-2
Acetophenone
0,043
0.32 J
mg/kg
BH-18
2120
0.018-1.3
3.20E-01
NV
1.00E+04
n
1.00E+04
N
BSL
100-52-7
Benzaldehyde
0.11 J
1.7
mg/kg
BH-18
3/20
0.074-5.1
1.70E+00
NV
1.00E+04
n
1.00E+04
N
BSL
98-82-8
Isopropylbenzene
0.091
0.091
mg/kg
BH-15
1/17
0.0009-0.005
9.10E-02
NV
2.10E+02
n
2.10E+02
N
BSL
75-09-2
Methylene Chloride
0.003 J
0.046
mg/kg
B-SS-1
9/28
0.002-0.013
4.60E-02
NV
9.60E+02
c
9.60E+02
N
BSL
100-42-5
Styrene
0,009 J
0.009 J
mg/kg
BH-20
1/22
0.0009-15
9.00E-03
NV
3.60E+03
n
3.60E+03
N
BSL
127-18-4
Tetrachloroethene
0,004 J
0.12 D
mg/kg
D-SS-1
5/25
0.0009-0.013
1.20E-01
NV
1.10E+02
c
1.10E+02
N
BSL
108-88-3
Toluene
0,045 J
0.28 D
mg/kg
B-SS-1
6/25
0.0009-0.012
2.80E-01
NV
4.50E+03
n
4.50E+03
N
BSL
79-01-6
Trichloroethylene
0.002 J
0.047 J
mg/kg
D-SS-1
3/28
0.0009-12
4.70E-02
NV
6.00E-01
c
6.00E-01
N
BSL
-F'-l-n j.i,- - 11 10 f I 2 4 E' C I-j< I .BE I' .1 j J,
-------
RAGS TABLE 7-1d
OCCURRENCE. DISTRIBUTION. AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 2 (SITEWIDE) - SURFACE SOIL
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY. NORTH CAROLINA
Scenario: Current/Future
Medium: Soil
Exposure Medium: Surface Soil jO-1 ft bgs)
Minimum
Maximum
Location of
Concentration
Potential
USEPA Industrial
Screening
COPC
Rationale for
Exposure Point
CAS Number
Chemical
Detected
Detected
Units
Detection
Range of
Used for
ARAR/TBC
Selection or
Concentration
CD
Concentration
(1)
Maximum
Concentration
Frequency
Detection Limits
Screening
(2)
Value
(3)
SOU HoL
(4)
Toxicity Value
(5)
Flag
(Y/N)
Deletion
m
Exposure Unit 2
SVOCs
Surface Soil
92-52-4
1.1'-Biphenyl
0,058
1.8
mg/kg
BH-15
5/20
0.018-1.3
1.60E+00
NV
2.00E+01
n
2.00E+01
N
BSL
(continued)
91-57-6
2-Methyinaphthalene
0,0039 J
4.1
mg/kg
BH-05
20/32
0.0075-4.8
4.10E+00
NV
2.20E+02
n
2.20E+02
N
BSL
83-32-9
Acenaphthene
0,00088 J
10
mg/kg
BH-15
15/32
0.0008-4.8
1.00E+01
NV
3.30E+03
n
3.30E+03
N
BSL
208-98-8
Acenaphthylene
0.00047 J
0,53
mg/kg
BH-26
20/32
0.0038-4.8
5.30E-01
NV
NV
NV
Y
NTX
120-12-7
Anthracene
0.00082 J
18
mg/kg
BH-15
25/32
0.0046-4.8
1.80E+01
NV
1.70E+04
n
1.70E+04
N
BSL
58-55-3
Benz[a]anthracene
0.0034
100
mg/kg
BH-26
28/32
0.38-0.43
1.00E+02
NV
2.10E+00
c
2.10E+00
Y
ASL
50-32-8
Benzo[a]pyrene
0.0035
100
mg/kg
BH-26
28/32
0.0075-4.8
1.00E+02
NV
2.10E-01
c
2.10E-01
Y
ASL
205-99-2
Benzolbjfluoranthene
0.0074
190
mg/kg
BH-26
27/31
0.38-4.8
1.90E+02
NV
2.10E+Q0
c
2.10E+00
Y
ASL
191-24-2
Benzo[g.h,i]perylene'
0.0027
24
mg/kg
BH-26
25/32
0.0075-4.8
2.40E+01
NV
1.70E+03
n
1.70E+03
N
BSL
207-08-9
Benzo[k]flucranthene
0.0031
63
mg/kg
BH-26
26/32
0.0075-4.8
6.30E+01
NV
2.10E+01
c
2.10E+01
Y
ASL
117-81-7
bis(2-Ethyihexyl)Phthalate
0.096 J
1500
mg/kg
BH-04
25/28
0.074-1500
1.50E+03
NV
1.20E+02
c
1.20E+02
Y
ASL
85-88-7
Butylbenzylphthalate
0.29 J
8.2 D
mg/kg
E-SS-1
3/28
0.074-5.1
8.20E+00
NV
9.10E+02
c
9.10E+02
N
BSL
88-74-8
Carbazole
0.042 J
11
mg/kg
BH-05
8/28
0.018-4.8
1.10E+01
NV
NV
NV
Y
NTX
218-01-9
Chrysene
0.0033 J
98
mg/kg
BH-26
27/32
0.38-4.8
9.60E+01
NV
2.10E+02
c
2.10E+02
N
BSL
53-70-3
Dibenz[a,h]anthracene
0,00093 J
11
mg/kg
BH-26
18/28
0.0037-430
1.10E+01
NV
2.10E-01
c
2.10E-01
Y
ASL
132-84-9
Dibenzofuran
0.15
12
mg/kg
BH-15
8/28
0.018-4800
1.20E+01
NV
1.00E+02
n
1.00E+02
N
BSL
131-11-3
Dimethyl Phthalate'-1
0.78 J
0.78 J
mg/kg
BH-14
1/23
0.074-430
7.80E-01
NV
4.90E+03
4.90E+03
N
BSL
117-84-0
Di-n-octylphthalate
0.26 J
5.1 J
mg/kg
BH-05
5/25
0.074-5.1
5.10E+00
NV
6.20E+02
n
6.2QE+02
N
BSL
206-44-0
Fluoranthene
0.005
160
mg/kg
BH-26
28/32
0.38-0.43
1.60E+02
NV
2.20E+03
n
2.20E+03
N
BSL
88-73-7
Fluorene
0.0025 J
10
mg/kg
BH-15
17/32
0.0008-4.8
1.00E+01
NV
2.20E+03
n
2.20E+03
N
BSL
193-39-5
lndeno[ 1,2.3-cd]pyrene
0.0022
31
mg/kg
BH-26
25/32
0.0075-4.8
3.10E+01
NV
2.10E+00
c
2.10E+00
Y
ASL
91-20-3
Naphthalene
0.0034 J
6.8
mg/kg
BH-Q3
21/32
0.0075-4.8
6.60E+00
NV
1.80E+01
c
1.80E+01
N
BSL
98-95-3
Nitrobenzene
0.22 J
0.22 J
mg/kg
BH-18
1/24
0.018-430
2.20E-01
NV
2.40E+01
c
2.40E+01
N
BSL
85-01-8
Phenanthrene'1
0.0081 J
58
mg/kg
BH-26
28/32
0.38-0.43
5.80E+01
NV
1.70E+04
n
1.70E+04
N
BSL
108-95-2
Phenol
0.84
1.3
mg/kg
BH-19
2/20
0.018-1.3
1.30E+00
NV
1.80E+04
n
1.80E+04
N
BSL
129-00-0
Pyrene
0.0042
150
mg/kg
BH-26
28/32
0.38-0.43
1.50E+02
NV
1.70E+03
n
1.70E+03
N
BSL
PCBs
11097-89-1
Aroclor-1254
0,031 J
110
mg/kg
BH-18
13/32
0.0037-1.5
1.10E+02
NV
7.40E-01
c
7.40E-01
Y
ASL
11096-82-5
Aroclor-1260
0.01 J
3.7
mg/kg
BH-03
13/32
0.0037-3.3
3.70E+00
NV
7.40E-01
c
7.40E-01
Y
ASL
Notes:
(1) J - estimated value: JN - presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions.
D - discrepancies between reported concentrations may be due to dilution of the sample or extract. B - constituent was also found in associated
method blank. U - reading was below method detection limit.
(2) Concentration used for screening is the maximum detected concentration.
(3) No ARAR values were considered for this exposure medium,
(4) USEPA Industrial Soil RSLs (May 2014): c = Cancer RSL; n = Noneancer RSL: NV = No value, Noncancer RSLs adjusted by multiplying RSL by 0.1.
(5) The Screening Toxicity Value represents the USEPA Industrial Soil RSLs table value,
(6) Selection Rationale: ASL - Above Screening Level: NTX - No Toxicity Information. Deletion Rationale: BSL - Below Screening Level,
Definitions:
ARAR: Applicable or Relevant and Appropriate Requirements
CAS: Chemical Abstact Service
COPC: Chemical of Potential Concern
NUT: Chemical is an essential nutrient and is not screened in
RSL: Regional Screening Level: USEPA, 2014
TBC: To Be Considered
USEPA: United States Environmental Protection Agency
a = RSL value for chromium (III) applied; hexavaient chromium not detected in any site samples,
b = RSL value for chlordane used,
c = RSL value for b-BHC used,
d = RSL value for endosulfan used,
e = RSL value for endrin used,
f = RSL value for pyrene used,
g = RSL for diethyl phthalate used,
h = RSL for anthracene used.
= Chemical detected in 100% of samples.
Constituents of Chlordane includes all isomers detected.
i .< f-i-d - ii in i;• 4 E'C :u
-------
RAGS TABLE 7-1e
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 3 (PAILIN CREEK) - SEDIMENT
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NORTH CAROLINA
Scenario; Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
«D
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Residential
Soil RSL
(4)
Screening
Toxicity Value
(5)
COPC
Flag
(Y/N)
Rationale for
Selection or
Deletion
(6)
Pailin Creek
METALS
Sediment
7429-90-5
Aluminum
13300 J
77900 J
mg/kg
PC-2-SD
7/7
-
7.79E+04
NV
7.70E+03
n
7.70E+03
Y
ASL
7440-38-0
Antimony
0.582 J
0,582 J
mg/kg
PC-6-SD
1/7
0.233-0.458
5.82E-01
NV
3.10E+00
n
3.10E+00
N
BSL
7440-38-2
Arsenic
3,54 J
25.1 J
mg/kg
PC-2-SD
7/7
.
2,51 E+01
NV
6.10E-01
c
6.10E-01
Y
ASL
7440-39-3
Barium
58,5 J
317 J
mg/kg
PG-2-SD
7/7
-
3,17E+02
NV
1.50E+03
n
1.50E+03
N
BSL
7440-41-7
Beryllium
0,435
1,34 J
mg/kg
PC-2-SD
7/7
-
1.34E+00
NV
1.60E+01
n
1.60E+01
N
BSL
7440-43-9
Cadmium
0,16 J
3,39
mg/kg
PC-6-SD
7/7
-
3.39E+00
NV
7.00E+00
n
7.00E+00
N
BSL
7440-70-2
Calcium
2290 J
4840 J
mg/kg
PC-2-SD
7/7
.
4.84E+03
NV
NV
NV
N
NUT
7440-47-3
Chromium'
8,38 J
257 J
mg/kg
PC-6-SD
9/9
-
2.57E+02
NV
1.20E+04
n
1.20E+04
N
BSL
7440-48-4
Cobalt
6.69
32,2
mg/kg
PC-6-SD
7/7
.
3.22E+01
NV
2.30E+00
n
2.30E+00
Y
ASL
7440-50-8
Copper
17,4 J
57,4
mg/kg
PG-6-SD
7/7
-
5.74E+01
NV
3.10E+02
n
3.10E+02
N
BSL
7439-89-6
Iron
13600 J
29800 J
mg/kg
PC-5-SD
7/7
-
2.98E+04
NV
5.50E+03
n
5.50E+03
Y
ASL
7439-92-1
Lead
23.7 J
154 J
mg/kg
PC-6-SD
7/7
-
1.54E+02
NV
4.00E+02
n
4.00E+02
N
BSL
7439-95-4
Magnesium
2920 J
7020 J
mg/kg
PC-2-SD
7/7
.
7.02E+03
NV
NV
NV
N
NUT
7439-96-5
Manganese
122 J
204 J
mg/kg
PC-7-SD
7/7
-
2.04E+02
NV
1.80E+02
n
1.80E+02
Y
ASL
7439-97-6
Mercury
0.0495 J
0,176 J
mg/kg
PC-2-SD
7/7
-
1.76E-01
NV
1.00E+01
n
1.00E+01
N
BSL
7440-02-0
Nickel
11
36,1 J
mg/kg
PC-2-SD
7/7
-
3.61 E+01
NV
1.50E+02
n
1.50E+02
N
BSL
7440-09-7
Potassium
1230
3800 J
mg/kg
PC-2-SD
7/7
.
3.80E+03
NV
NV
NV
N
NUT
7782-49-2
Selenium
0.286 J
1.32 J
mg/kg
PC-2-SD
7/7
-
132E+00
NV
3.90E+01
n
3.90E+01
N
BSL
7440-22-4
Silver
0,0529
1,26
mg/kg
PC-4
7/7
-
1.26E+00
NV
3.90E+01
n
3.90E+01
N
BSL
7440-23-5
Sodium
1530
6140 J
mg/kg
PC-5-SD
7/7
-
6.14E+03
NV
NV
NV
N
NUT
7440-28-0
Thallium
0.119 J
0,937 J
mg/kg
PC-2-SD
7/7
.
9.37E-01
NV
7.80E-02
n
7.80E-02
Y
ASL
7440-82-2
Vanadium
15.2 J
76,6 J
mg/kg
PC-2-SD
7/7
-
7.66E+01
NV
3.90E+01
n
3.90E+01
Y
ASL
7440-66-6
Zinc
74,5 J
665
mg/kg
PC-6-SD
7/7
-
6.65E+02
NV
2.30E+03
n
2.30E+03
N
BSL
PESTICIDES
72-54-8
4-4-DDD
0.011 J
0,062 J
mg/kg
PC-2-SD
4/7
0.012-0.021
6.20E-02
NV
2.00E+00
c
2.00E+00
N
BSL
72-55-9
4-4-DDE
0.011 J
0.16 J
mg/kg
PG-2-SD
6/7
0,11-0.11
1.60E-01
NV
1.40E+00
c
1.40E+00
N
BSL
50-29-3
4-4-DDT
0,0036 J
1,1
mg/kg
PC-4
6/7
0,012-0.012
1.10E+00
NV
1.70E+00
c
1.70E+00
N
BSL
309-00-2
Aldrin
0,0027 J
0,072 J
mg/kg
PC-1-SD
6/7
0.011-0.011
7.20E-02
NV
2.90E-02
c
2.90E-02
Y
ASL
60-57-1
Dieldrin
0,0057 J
0,26
mg/kg
PC-4
3/7
0,0022-0,035
2.60E-01
NV
3.00E-02
c
3.00E-02
Y
ASL
1031-07-8
Endosulfan Sulfate'5
0.024 J
0 024 J
mg/kg
PC-6-SD
1/7
0,0022-0.11
2.40E-02
NV
3.70E+01
n
3.70E+01
N
BSL
7421-93-4
Endrin Aldehyde
0,0052 J
0,069 J
mg/kg
PC-5-SD
5/7
0.011-0,021
g goE-02
NV
1.80E+00
n
1.80E+00
N
BSL
76-44-8
Heptachior
0.0066 JN
0.0066 JN
mg/kg
PC-1-SD
1/7
0.0021-0,03
6.60E-03
NV
1.10E-01
c
1.10E-01
N
BSL
1024-57-3
Heptachior Epoxide
0,0043 J
0,043 J
mg/kg
PC-7-5D
5/7
0,0059-0,011
4.30E-02
NV
5.30E-02
c
5.30E-02
N
BSL
58-89-9
Lindane
0.002 J
0,026 JN
mg/kg
PC-6-SD
1/7
0,0021-0,029
2 60E 02
NV
g 20E-01
c
5.20E-01
N
BSL
5103-74-2
trans-Chlordane'1
0.016
0.028
mg/kg
PC-6-SD
3/7
0.0055-0.027
2.80E-02
NV
1.60E+00
c
1.60E+00
N
BSL
VOCs
95-50-1
1,2-Dichlorobenzene
0,014
0.014
mg/kg
PC-6-SD
1/1
-
1.40E-02
NV
1.90E+02
n
1.90E+02
N
BSL
541-73-1
1,3-Dichiorobenzene"
0.003 J
0,003 J
mg/kg
PC-6-SD
1/1
-
3.00E-03
NV
2.40E+00
c
2.40E+00
N
BSL
106-46-7
1,4-Dichiorobenzene
0,011
0.011
mg/kg
PC-6-SD
1/1
.
1.10E-02
NV
2.40E+00
c
2.40E+00
N
BSL
78-93-3
2-Butanone
0.017 J
0,046 J
mg/kg
PC-2-SD
3/7
0.008-0.021
4.60E-02
NV
2.80E+03
n
2.80E+03
N
BSL
67-64-1
Acetone
0.025 J
0,19 J
mg/kg
PC-2-SD
7/7
-
1.90E-01
NV
6.10E+03
n
6.10E+03
N
BSL
100-52-7
Benzaldehyde
0.59 J
0,59 J
mg/kg
PC-1-SD
1/7
0.27-0.83
5.90E-01
NV
7.80E+02
n
7.80E+02
N
BSL
71-43-2
Benzene
0.002 J
0,002 J
mg/kg
PC-6-SD
1/7
0.001-0.003
2.00E-03
NV
1.10E+00
c
1.10E+00
N
BSL
75-15-0
Carbon Disulfide
0.004 J
0,004 J
mg/kg
PC-3
1/7
0,002-0.006
4.00E-03
NV
8.20E+01
n
8.20E+01
N
BSL
108-90-7
Chlorobenzene
5,4
5.4
mg/kg
PC-6-SD
1/7
0.003-0.006
5.40E+00
NV
2.90E+01
n
2.90E+01
N
BSL
110-82-7
Cyclohexane
0.002 J
0.002 J
mg/kg
PC-6-SD
1/7
0.003-0.006
2.00E-03
NV
7.00E+02
n
7.00E+02
N
BSL
75-65-0
Tert-Butyl Alcohol'
0,14 J
0.14 J
mg/kg
PC-2-SD
1/5
0.04-0.066
1.40E-01
NV
6.10E+03
n
6.10E+03
N
BSL
i - To-Pi Dc» f-ej'oa hhp- P'oniiKieiii file i i-iu- u Li i MifMite tii'ie p* i ion Tit.ie - en:» iwn -i ;• $ Page 1 of 2 O'Brien & Gere
-------
RAGS TABLE 7-1e
OCCURRENCE, DISTRIBUTION, AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 3 (PAILIN CREEK) - SEDIMENT
FORMER TRIANGLE PACIFIC SITE
ELIZABETH CITY, NORTH CAROLINA
Scenario; Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
CAS Number
Chemical
Minimum
Detected
Concentration
(1)
Maximum
Detected
Concentration
«D
Units
Location of
Maximum
Concentration
Detection
Frequency
Range of
Detection Limits
Concentration
Used for
Screening
(2)
Potential
ARAR/TBC
Value
(3)
USEPA Residential
Soil RSL
(4)
Screening
Toxicity Value
(5)
COPC
Flag
(Y/N)
Rationale for
Selection or
Deletion
(6)
Pailin Creek
SVOCs
Sediment
92-52-4
1,1'-Biphenyl
0,45
0,45
mg/kg
PC-6-SD
1/7
0,11-0.21
4.50E-01
NV
4.70E+00
n
4.70E+00
N
BSL
91-57-6
2-Methylnaphthalene
0.028 J
1.2
mg/kg
PC-6-SD
2/7
0.012-0.042
1.20E+00
NV
2.30E+01
n
2.30E+01
N
BSL
83-32-9
Acenaphthene
1 J
5.2
mg/kg
PC-6-SD
2/7
0.012-0.042
5.20E+00
NV
3.40E+02
n
3.40E+02
N
BSL
208-96-8
Acenaphthylene
0.012 J
0,52 J
mg/kg
PC-3
4/7
0.006-0.021
5.20E-01
NV
NV
NV
Y
NTX
120-12-7
Anthracene
0.015 J
12
mg/kg
PC-6-SD
5/7
0.011-0.021
1.20E+01
NV
1.70E+03
n
1.70E+03
N
BSL
56-55-3
Benz[a]arrthracene
0.041 J
20
mg/kg
PC-6-SD
5/7
0,022-0.042
2.00E+01
NV
1.50E-01
c
1.50E-01
Y
ASL
50-32-8
Benzo[a]pyrene
0.042 J
17
mg/kg
PC-8-SD
5/7
0.022-0.042
1.70E+01
NV
1.50E-02
c
1.50E-02
Y
ASL
205-99-2
Benzo[b]fluoranthene
0.042 J
26
mg/kg
PC-6-SD
5/7
0.022-0.042
2.60E+01
NV
1.50E-01
c
1.50E-01
Y
ASL
191-24-2
Benzcfg, h, ijpery lene'1
0.016 J
6
mg/kg
PC-6-SD
5/7
0,022-0,042
6.00E+00
NV
1.70E+02
n
1.70E+02
N
BSL
207-08-9
Be nzo[k]fl uora nthene
0.032 J
11
mg/kg
PC-6-SD
7/7
.
1.10E+01
NV
1.50E+00
c
1.50E+00
Y
ASL
117-81-7
bis(2-Ethylhexyl)Phthalate
0.54 J
66
mg/kg
PC-6-SD
5/7
0,44-0.83
6.60E+01
NV
3.50E+01
c
3.50E+01
Y
ASL
86-74-8
Carbazole
2,7 J
5,4
mg/kg
PC-6-SD
2/7
0,11-0.21
5.40E+00
NV
NV
NV
Y
NTX
218-01-9
Chrysene
0.025 J
20
mg/kg
PC-8-SD
5/7
0.011-0.021
2.00E+01
NV
1.50E+01
c
1.50E+01
Y
ASL
53-70-3
Dibenz[a,h]anthracene
0.024 J
1.8
mg/kg
PC-6-SD
4/7
0.012-0,042
1.80E+00
NV
1.50E-02
c
1.50E-02
Y
ASL
132-64-9
Dibenzofuran
0,66 J
2.8
mg/kg
PC-6-SD
2/7
0,11-0.21
2.80E+00
NV
7.80E+00
n
7.80E+00
N
BSL
206-44-0
Fluora nthene
0.039 J
61
mg/kg
PC-6-SD
5/7
0,022-0.042
6.10E+01
NV
2.30E+02
n
2.30E+02
N
BSL
86-73-7
Fluorene
0.9 J
5.2
mg/kg
PC-6-SD
2/7
0.012-0.042
5.20E+00
NV
2.30E+02
n
2.30E+02
N
BSL
193-39-5
indeno[1,2,3-cd]pyrene
0.016 J
6.6
mg/kg
PC-6-SD
5/7
0,022-0,042
6.60E+00
NV
1.50E-01
c
1.50E-01
Y
ASL
91-20-3
Naphthalene
0.064 J
3.8
mg/kg
PC-6-SD
2/7
0.012-0.042
3.80E+00
NV
3.60E+00
c
3.60E+00
Y
ASL
85-01-8
Phenanthrenels
0.034 J
46
mg/kg
PC-6-SD
5/7
0,022-0,042
4.60E+01
NV
1.70E+03
n
1.70E+03
N
BSL
129-00-0
Pyrene
0.035 J
45
mg/kg
PC-6-SD
5/7
0,022-0.042
4.50E+01
NV
1.70E+02
n
1.70E+02
N
BSL
PCBs
11097-69-1
Arocior-1254
0,28 J
0,28 J
mg/kg
PC-6-SD
1/7
0,011-0,059
2.80E-01
NV
2.20E-01
c
2.20E-01
Y
ASL
11096-82-5
Arocior-1260
0.28
0,28
mg/kg
PC-6-SD
1/7
0,011-0,059
2.80E-01
NV
2.20E-01
c
2.20E-01
Y
ASL
Notes:
(1) J - estimated value; JN - presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions.
(2) Concentration used for screening Is the maximum detected concentration,
(3) No ARAR values were considered for this exposure medium.
(4) USE PA Residential Soil RSLs (May 2014); c = Cancer RSL; n = Noncancer RSL; NV = No value. Noncancer RSLs adjusted by multiplying RSL by 0.1.
(5) The Screening Toxicity Value represents the USEPA Industrial Soli RSLs table value.
(6) Selection Rationale: ASL - Above Screening Level; NTX - No Toxicity Information. Deletion Rationale: BSL - Below Screening Level.
a = RSL value for chromium (III) applied; hexavalent chromium not detected in any site samples,
b = RSL value for endosulfan used,
c = RSL value for endrin used,
d = RSL value for chlordane used,
e = RSL value for 1,4-dichlorobenzene used,
f = RSL value for N-butanol used,
g = RSL value for pyrene used,
h = RSL value for anthracene used.
Definitions:
ARAR: Applicable or Relevant and Appropriate Requirements
CAS: Chemical Abstact Service
CO PC: Chemical of Potential Concern
NUT: Chemical is an essential nutrient and is not screened in
RSL: Regional Screening Level; USEPA, 2014
TBC: To Be Considered
USEPA: United States Environmental Protection Agency
= Chemical detected in 100% of samples.
Constituents of Chlordane includes all isomers detected.
i - To-Pi Dc» f-ej'oa hhp- Puftiiineiii file 11 -1 o- ij Li i MifMite Tine p* , (on Tit.ie ;• *¦ - Ł><;, :¦> iwn -i ;• 5 Page 2 of 2 O'Brien & Gere
-------
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At L
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rj
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C'-hnih. .n-,
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1 in jirr; \ii~ ^ruf
= <* h—n u« fit .|-i— i—. I in 1"
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i-, F'-« •. . ~ E" .vv..«wr.xr_»
-------
ftp-it TABLE "-1-1
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''Bd-li •.yj"
-------
RAOS TABLE 7-1h
OCCURRENCE, DISTRIBUTION, AN[) SELECTION OF CHEMICALS OF POTENTIAL CONCERN - EXPOSURE UNIT 3(PAILIN CREEK) - BLUE CRAB TISSUE
FORMER TRIANOLE PACIFIC: SITE
ELIZABETH CITY, NURTH CAROLINA
Scwwrl i Cuwrf F iIufp
MhIIiiii T1s»»iip
Ex[nii,Uf»> Mwllum Bltf* CrMi
ExjMteuBtM
GAS Nunto
Minimum
Onr^itm\bm
(1J
Maximum
G UTOHUralim
cu
Urtb
Li ic^N'nol
Maslnnjni
O mcpnlr^lH «n
Frwjupmy
Ramj^ * *!
OMinfiLlmlb
O inoHilralN'n
if
Scr^nlfij
(2)
PiMprtlal
abartbc
Valiip
<3j
USEPA RSL l< >r
Fbh loy^lNi
(4)
Scr^nifny
T< ~xlcily Vali*»
(S>
(X)PC
fl'.l
(YN)
Rali inalp li ir
SpN;IIi in i ir
EMrtNl
(2)
Pailin Orppk
METALS
BIiip Orah Tb^jM
7424-4E 02
Y
B
4L
72-SS-4
4 4 DDE
IMWIIfiS J
IMNMftJ
niy ky
RH
12
44
1 fHtE-03
NV
4 3(E 03
c
4 30E-03
Y
Efr
r RSL, n - Niroarow RSL, NV - Nci valiip
Nim career RSLt. ail|iis.l«l tiy nrulll[ilylncj RSL tiy It 1
(5) Thp Scrwiiny TiixWly Vaki»»r»»iirm.MTi& Ilv USEPA RNjii trial Scrwnlnj LwM Ffc.li Inywlltti TatiN ralup
(ft) Sf»l«;ll111 RailI(ialf» ASL • Attiw» Scrwllfilj Lewi, NTX • Nil Titxiely Irilitrmalliill EMrtkillRatlirialp BSL • Beliw ScreeiilrnJ Level
[Miniliiitft
ARAB A|(iU;ati^fir FMevanl an! Aliimififlale R«niirenienl:>
COPC Cl*»ml;al i ( Pi tienitol G iri:ern
NUT CJiert ileal Is. an es^enllal mHrh^rH ami Is. in il soiwnwl In
RSL Rttjiirial Saeerinj Lwl, USEPA, 21113
TBC TuBf CSnis.li Ifr«l
USEPA Unl«l Slales Erivln iriiiw^rtal Prolecltiri Aijt*n:y
NV - Mi value
a - Mercury Incrati Ibs-tp as,s.tmiMl In lie iiFes.nr! at, nrelliylniercury, FSSL Inr melhytniereury us.«I
li. RSL value liir wnlifeiilan us,eil
" = Cl*>nili;aliMedei 1 In iimp.hI samples,
.. Fr[|.. i-FfetF*-
r-rtv.. • Łu 'Wir,.,
-------
Table 7-2
Non-Cancer Toxicity Data - Oral/Dermal
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Chronic /
Subchronic
ORAL
RDF
Oral Absorption
Efficiency for Dermal
(unitless)
(1)
Absorbed RfD for Dermal
(2)
Primary Target Organ(s) /
Critical Effect(s) (3)
Combined
Uncertainty f Modifying
Factors
RfD:
Target Organ(s)
Value
Units
Value
Units
(Uncertainty)
(Modifying)
Source(s)
Date(s)
(MM/DD/YYVY)
METALS
ALUMINUM
Chronic
1.00E+00
mg/kg-day
1.00E+00
1.00E+00
mg/kg-day
Neurotoxicity
100
1
PPRTV
10/23/2006
ANTIMONY
Chronic
4.00E-04
mg/kg-day
1.50E-O1
6.00E-05
mg/kg-day
Longevity (M); Blood glucose (E); Cholesterol (E)
1000
1
IRIS
2/1/2008
ARSENIC
Chronic
3.00E-04
mg/kg-day
9.50E-01
3.00E-04
mg/kg-day
Hyperpigmentation (In); Vascular (V); PNS (N)
3
1
IRIS
2/1/2008
BARIUM
Chronic
2.00E-01
mg/kg-day
7.00E-02
1.40E-02
mg/kg-day
Humans - none observed (0); Rats - Kidney (R)
3
1
IRIS
2/1/2008
CADMIUM
Chronic
1.00E-03
mg/kg-day
2.50E-02
2.50E-Q5
mg/kg-day
Renal (R); Significant Proteinuria
10
1
IRIS
2/1/2008
CHROMIUM, TOTAta
Chronic
1.50E+00
mg/kg-day
1.30E-02
2.00E-02
mg/kg-day
None reported (0)
100
10
IRIS
1/15/2010
COBALT
Chronic
3.00E-04
mg/kg-day
1.00E+00
3.00E-04
mg/kg-day
NA
NA
NA
PPRTV
10/23/2006
COPPER
Chronic
4.00E-02
mg/kg-day
1.00E+00
4.00E-02
mg/kg-day
Gastrointestinal effects
1
1
HEAST (STSC)
6/19/1997
IRON
Chronic
7.00E-01
mg/kg-day
1.00E+00
7.00E-01
mg/kg-day
Gastrointestinal effects
2
1
PPRTV
9/11/2006
LEAD
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MANGANESE (Non-diet)
Chronic
2.40E-02
mg/kg-day
4.00E-02
9.60E-04
mg/kg-day
CNS(N)
1
3
IRIS
2/1/2008
MANGANESE (Diet)
Chronic
1.40E-01
mg/kg-day
4.00E-02
5.60E-03
mg/kg-day
CNS(N)
1
1
IRIS
2/1/2008
MERCURYb
Chronic
3.00E-04
mg/kg-day
8.00E-01
3.00E-04
mg/kg-day
Developmental, neuropsychological
1000
1
IRIS (mercuric
chloride/other salts)
1/16/2008
METHYLMERCURY
Chronic
1.00E-04
mg/kg-day
9.50E-01
1.00E-04
mg/kg-day
Developmental, neuropsychological
10
1
IRIS
7/27/2001
NICKEL
Chronic
2.00E-02
mg/kg-day
4.00E-02
8.00E-04
mg/kg-day
Decreased body and organ weight (W)
300
1
IRIS
2/1/2008
SELENIUM
Chronic
5.00E-03
mg/kg-day
8.00E-01
5.00E-03
mg/kg-day
Clinical selenosis
3
1
IRIS
2/1/2008
SILVER
Chronic
5.00E-03
mg/kg-day
4.00E-02
2.00E-04
mg/kg-day
Argyria (In)
3
1
IRIS
2/1/2008
THALLIUM
Chronic
1.00E-05
mg/kg-day
1.00E+00
1.00E-05
mg/kg-day
Hair follicle atrophy
3000
1
PPRTV
10/25/2012
VANADIUM
Chronic
5.00E-03
mg/kg-day
2.60E-02
1.30E-04
mg/kg-day
Decreased hair cystine
100
1
IRIS
2/1/2008
ZINC
Chronic
3.Q0E-01
mg/kg-day
1.00E+00
3.00E-Q1
mg/kg-day
Decreased ESOD (B)
3
1
IRIS
2/1/2008
PCBs
AROCLOR 1248
NA
NA 2.0E-05
NA
NA 9.6E-01
NA 2.0E-05
NA
NA
NA 300
N A 1
NA IRIS
NA 2/1/2008
AROCLOR 1254
Chronic NA
NA
mg/kg-day NA
NA
NA
mg/kg-day NA
Ocular exudate (OC), inflamed and prominent Meibomian
glands, distorted growth of finger and toe nails; decreased
antibody (IgG and IgM) response to sheep erythrocytes
NA
NA
NA
NA
AROCLOR 1260
NA
PESTICIDES
4-4-DDT
Chronic
5.00E-04
mg/kg-day
9.00E-01
5.00E-04
mg/kg-day
Liver lesions (H)
100
1
IRIS
2/1/2008
4-4-DDD
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4-4-DDE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
A-BHC
Chronic
8.Q0E-03
mg/kg-day
1.00E+00
8.00E-03
mg/kg-day
NA
100
1
ATSDR (STSC)
7/1/2006
ALDRIN
Chronic
3.00E-05
mg/kg-day
1.00E+00
3.00E-05
mg/kg-day
Liver toxicity (H)
1000
1
IRIS
2/1/2008
CHLORDANE
Chronic
5.00E-04
mg/kg-day
8.00E-01
5.00E-04
mg/kg-day
Neurotoxicity and hematotoxicity,
300
1
IRIS
4/28/2008
DIELDRIN
Chronic
5.00E-05
mg/kg-day
1.00E+00
5.00E-05
mg/kg-day
Hepatic (H)
100
1
IRIS
2/1/2008
Reduced body weight gain in males and females
(W); increased incidence of marked progressive
glomerulonephrosis and blood vessel aneurysms in
males (B)
ENDOSULFAN II
Chronic
6.00E-03
mg/kg-day
1.00E+00
6.00E-Q3
mg/kg-day
100
1
IRIS (Endosulfan as
surrogate)
2/1/2008
SVOCs
ACENAPHTHYLENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(A)ANTHRACENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(A)PYRENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(B)FLUORANTHENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BENZO|K)FLUORANTHENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BIS(2-ETHYLHEXYL)PHTHALATE
Chronic
2.00E-02
mg/kg-day
8.90E-01
2.00E-02
mg/kg-day
Increased relative liver weight (H)
1000
1
IRIS
2/1/2008
Page 1 of 2
-------
Table 7-2
Non-Cancer Toxicity Data - Oral/Dermal
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Chronic /
Subchronic
ORAL
RDF
Oral Absorption
Efficiency for Dermal
(unitless)
(1)
Absorbed RfD for Dermal
(2)
Primary Target Organ(s) /
Critical Effect(s) (3)
Combined
Uncertainty / Modifying
Factors
RfD:
Target Organ(s)
Value
Units
Value
Units
(Uncertainty)
(Modifying)
Source(s)
Date(s)
(MM/DD/YYYY)
SVOCs Continued
CARBAZOLE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CHRYSENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DIBENZ(A,H)ANTHRACENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DIBENZOFURAN
Chronic
1.00E-03
mg/kg-day
1.00E+00
1.00E-03
mg/kg-day
Reduced length and organ weight. Excess
10000
1
PPRTV
6/11/2007
abdominal fat (0).
INDENO[l,2,3-CD]PYRENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NAPHTHALENE
Chronic
2.00E-02
mg/kg-day
8.90E-01
2.00E-02
mg/kg-day
Decreased body weight (W)
3000
1
IRIS
2/1/2008
VOCs
1,2-DICHLOROBENZENE
Chronic
9.00E-02
mg/kg-day
1.00E+00
9.00E-02
mg/kg-day
None reported (0)
1000
1
IRIS
8/22/2012
1,3-DICHLOROBENZENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,4-DICHLOROBENZENE
Chronic
7.00E-02
mg/kg-day
1.00E+00
7.00E-02
mg/kg-day
Liver
100
1
ATSDR (STSC)
7/1/2006
CIS-l,2-DICHLOROETHYLENE
Chronic
2.00E-03
mg/kg-day
1.00E+00
2.00E-03
mg/kg-day
Increased relative kidney weight in male rats (R)
3000
1
IRIS
8/22/2012
Notes:
(1) Oral Absorption Efficiency from Exhibit 4-1 of USEPA (2004) RAGS Part E. For constituents not listed in Exhibit 4-1, an absorption efficiency of 1 is assumed. For constituents with a range of absorption efficiencies in Exhibit 4-1, the highest value is reported.
(2) For Oral Absorption Efficiency for Dermal < 0.5, Absorbed RfD for Dermal = Oral RfD * Oral Absorption Efficiency for Dermal; otherwise, Absorbed RfD for Dermal = Oral RfD (USEPA 2004 RAGS Part E, Exhibit 4-1).
(3) Codes for Effects Endpoints: B - Hematological/Blood effect; E - Endocrine system effect; Gl - Gastrointestinal system; H - Hepatic/Liver effect; I - Immune system effect; In - Integumentary/Skin effect; M - Mortality/Death/Longevity; N - Nervous system effect O - Other effect (e.g., hyperactivity, none reported); OC - Ocular effect; R -
Renal/Kidney effect; T - Teratogenic effect; V - Vascular system effect; W - Decreased body weight.
a = Oral and dermal RfDs for trivalent chromium utilized (hexavalent chromium not detected in any samples at site), b = RfD for mercuric chloride and other mercury salts utilized.
NA - Not available
Sources:
Tier 1 - IRIS - United States Environmental Protection Agency (USEPA) Integrated Risk Information System (Available at: http://www.epa.gov/iris).
Tier 2 - PPRTV - USEPA Provisional Peer Reviewed Toxicity Values from the Office of Research and Development/National Center for Environmental Assessment/Superfund Health Risk Technical Support Center (STSC). Tier 3 - Tox values approved by Superfund Technical Support Center. ATSDR - Agency for Toxic Substances and Disease Registry
Minimal Risk Levels (MRLs. Available at: http://www.atsdr.cdc.gov/mrls/index.html):
CALEPA - California Environmental Protection Agency toxicity criteria database (Available at: http://www.oehha.ca.gOv/risk/chemicalDB//index.asp): HEAST - USEPA Health Effects Assessment Summary Tables from the USEPA STSC:
NCEA - National Center for Environmental Assessment;USEPA (2003). Memo from Southerland. OSWER Directive 9285.7-75. USEPA (1993) Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons, EPA/600/R-93/089).
STSC - Indicates that the associated value was provided for this assessment by the Superfund Technical Support Center.
Page 2 of 2
-------
Table 7-3
Non-Cancer Toxicity Data -- Inhalation
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of Potential Concern
Chronic /
Subehronic
Inhalation RfC
Primary Target Organ(s) / Critical Effect(s)
Combined
Uncertainty / Modifying
RfD:
Target ^3rgan(s)
Value
Units
(Uncertainty)
(Modifying)
Source(s)
Date(s)
(MM/DD/YYYY)
METALS
ALUMINUM
Chronic
5.00E-03
mg/m3
Psychomotor and cognatlve impairments
300
1
PPRTV
10/23/2006
ANTIMONY
NA
NA
NA
NA
NA
NA
NA
NA
ARSENIC
Chronic
1.50E-05
mg/m2
Development, cardiovascular, nervous system
NA
NA
CaiEPA fSTSCJ
2/4/2008
BARIUM
Chronic
5.00E-04
mg/m"
Renal toxicity
NA
NA
HEAST (STSC)
6/17/2005
CADMIUM
Chronic
1.00E-05
mg/m"
Increased risk of proteinuria
3
3
ATSDR
9/1/2012
CHROMIUM, TOTALa
NA
NA
NA
NA
NA
NA
NA
1/15/2010
COBALT
Chronic
6.00E-06
mg/m2
NA
NA
NA
PPRTV
10/23/2006
COPPER
NA
NA
NA
NA
NA
NA
NA
NA
IRON
NA
NA
NA
NA
NA
NA
NA
NA
LEAD
NA
NA
NA
NA
NA
NA
NA
NA
MANGANESE
Chronic
5.00E-05
mg/m3
Neurobehaviorai changes (M, 0)
1000
1
IRIS
2/4/2008
MERCURY
Chronic
3.00E-04
mg/m"
PNS (N); CNS (N)
30
1
IRIS, elemental
mercury
1/22/2008
NICKEL
Chronic
9.00E-05
mg/m3
Respiratory (P)
30
1
ATSDR (STSC)
9/1/2005
SELENIUM
Chronic
2.00E-02
mg/m*
NA
NA
NA
CaiEPA (STSC)
2/4/2008
SILVER
NA
NA
NA
NA
NA
NA
NA
NA
THALLIUM
NA
NA
NA
NA
NA
NA
NA
NA
VANADIUM
Chronic
1.00E-04
mg/m3
NA
NA
NA
ATSDR (STSC)
9/1/2005
ZINC
NA
NA
NA
NA
NA
NA
NA
NA
PCBs
AROCLOR 1248
NA
NA
NA
NA
NA
NA
NA
NA
AROCLOR 1254
NA
NA
NA
NA
NA
NA
NA
NA
AROCLOR 1260
NA
NA
NA
NA
NA
NA
NA
NA
PESTICIDES
4,4-DDT
NA
NA
NA
NA
NA
NA
NA
NA
4-4-DDD
NA
NA
NA
NA
NA
NA
NA
NA
4-4-DDE
NA
NA
NA
NA
NA
NA
NA
NA
A-BHC
NA
NA
NA
NA
NA
NA
NA
NA
ALDRIN
NA
NA
N A
NA
NA
NA
NA
NA
CHLORDANE
Chronic
7.00E-04
mg/m"
Neurotoxicity and hematoxicity.
1000
1
IRIS
4/28/2008
DIELDRIN
NA
NA
NA
NA
NA
NA
NA
NA
ENDOSULFAN II
NA
NA
NA
NA
NA
NA
NA
NA
Page 1 of 2
-------
Table 7-3
Non-Cancer Toxicity Data -- Inhalation
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of Potential Concern
Chronic/
Subchronic
Inhalation RfC
Primary Target Organ(s) / Critical Effect(s)
(1)
Combined
Uncertainty / Modifying
Factors
RfD:
Target Organ(s)
Value
Units
(Uncertainty)
(Modifying)
Source(s)
Date(s)
(MM/DD/YYYY)
SVOCs
ACENAPHTHYLENE
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(A)ANTHRACENE
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(A)PYRENE
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(B)FLUORANTHENE
NA
NA
NA
NA
NA
NA
NA
NA
BENZO(K)FLUORANTHENE
NA
NA
NA
NA
NA
NA
NA
NA
BIS(2-ETHYLHEXYL)PHTHALATE
NA
NA
NA
NA
NA
NA
NA
NA
CARBAZOLE
NA
NA
NA
NA
NA
NA
NA
NA
CHRYSENE
NA
NA
NA
NA
NA
NA
NA
NA
DIBENZ(A,H)ANTHRACENE
NA
NA
NA
NA
NA
NA
NA
NA
DIBENZOFURAN
NA
NA
NA
NA
NA
NA
NA
na ;
INDENO[l,2,3-CD]PYRENE
NA
NA
NA
NA
NA
NA
NA
NA
NAPHTHALENE
Chronic
3.00E-03
mg/m3
Nasal/respiratory (P)
3000
1
IRIS
2/4/2008
VOCs
1,2-DICHLOROBENZENE
Chronic
2.00E-01
mg/m3
NA
NA
NA
HEAST (STSC)
6/17/2005
1,3-DICHLOROBENZENE
NA
NA
NA
NA
NA
NA
NA
NA
1,4-DICHLOROBENZENE
Chronic
8.00E-01
mg/m3
Liver
100
1
IRIS
2/4/2008
CIS-1,2-DICHL0R0ETHYLENE
NA
NA
NA
NA
NA
NA
NA
NA
TRICHLOROETHYLENE
Chronic
2.00E-03
mg/m3
Decreased thymus weight (0) in female mice,
increased fetal cardiac malformations in rats (V)
10, 100
NA
IRIS
8/22/2012
Notes:
(1) Codes for Effects Endpoints: B - Hematological/Blood effect; E - Endocrine system effect; Gl - Gastrointestinal system; H - Hepatic/Liver effect; I - Immune system effect; In - Integumentary/Skin effect; M -
Mortality/Death/Longevity; N - Nervous system effect; O - Other effect (e.g., hyperactivity, none reported); OC - Ocular effect; R - Renal/Kidney effect; T - Teratogenic effect; V - Vascular system effect; W -
a = RfC for trivalent chromium utilized (hexavalent chromium not detected in any samples at site).
b = Hightly chlorinated PCBs includes Aroclors 1248,1254,1260 (and higher if reported). RfD value for Aroclor-1254 utilized. NA - Not available.
Sources:
Tier 1 - IRIS - United States Environmental Protection Agency (USEPA) Integrated Risk Information System (Available at: http://www.epa.gov/iris).
Tier 2 - PPRTV - USEPA Provisional Peer Reviewed Toxicity Values from the Office of Research and Development/National Center for Environmental Assessment/Superfund Health Risk Technical Support Center
Tier 3 - Tox values approved by Superfund Technical Support Center. ATSDR - Agency for Toxic Substances and Disease Registry Minimal Risk Levels (MRLs. Available at:
http://www.atsdr.cdc.gov/mrls/index.html): CALEPA - California Environmental Protection Agency toxicity criteria database (Available at: http://www.oehha.ca.gOv/risk/chemicalDB//index.asp): HEAST -
USEPA Health Effects Assessment Summary Tables from the USEPA STSC: NCEA - National Center for Environmental Assessment: USEPA (2003). Memo from Southerland. OSWER Directive 9285.7-
STSC - Indicates that the associated value was provided for this assessment by the Superfund Technical Support Center.
Page 2 of 2
-------
Table 7-4
Cancer Toxicity Data - Oral/Dermal
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Oral Cancer
Slope Factor
Oral Absorption
Efficiency for Dermal
(Unitless)
(1)
Absorbed Cancer Slope Factor
for Dermal (2)
Weight of Evidence/ Cancer Guideline Description
m
Oral Cancer Slope Factor
Value
Units
Value
Units
Source(s)
(MM/DD/YYYY)
METALS
ALUMINUM
NA
NA
NA
NA
NA
NA
NA
NA
ANTIMONY
NA
NA
NA
NA
NA
NA
NA
NA
ARSENIC
1.50E+00
(mg/kg-day)1
9.50E-01
1.50E+00
(mg/kg-day)1
A
IRIS
2/4/2008
BARIUM
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
CADMIUM
NA
NA
NA
NA
NA
B1
IRIS
2/4/2008
CHROMIUM, TOTAL4
NA
N A
NA
NA
NA
D
IRIS
1/15/2010
COBALT
NA
NA
NA
NA
NA
NA
NA
NA
COPPER
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
IRON
NA
NA
NA
NA
NA
NA
NA
NA
LEAD
NA
NA
NA
NA
NA
B2
IRIS
4/29/2008
MANGANESE
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
MERCURY
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
NICKEL
NA
NA
NA
NA
NA
NA
NA
NA
SELENIUM
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
SILVER
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
THALLIUM
NA
NA
NA
NA
NA
D
IRIS (thallium chloride)
2/4/2008
VANADIUM
NA
NA
NA
NA
NA
NA
NA
NA
ZINC
NA
NA
NA
NA
NA
NA
NA
NA
PCBs
AROCLOR 1248
2.00E+00
(mg/kg-day)1
9.60E-01
2.00E+Q0
(mg/kg-day)1
No IRIS eval,, used upper bound PCBs (B2)
IRIS
2/4/2008
AROCLOR 1254
2.00E+00
(mg/kg-day)1
9.60E-01
2.00E+00
(mg/kg-day)1
No IRIS eval,, used upper bound PCBs (B2)
IRIS
2/4/2008
AROCLOR 1260
2.00E+00
(mg/kg-day)1
9.60E-01
2.00E+00
(mg/kg-day)1
No IRIS eval,, used upper bound PCBs (B2)
IRIS
2/4/2008
PESTICIDES
4,4-DDT
3.40E-01
(mg/kg-day)1
9.00E-Q1
3.40E-01
(mg/kg-day)1
B2
IRIS
2/4/2008
4-4-DDD
2.40E-01
(mg/kg-day)1
1.00E+00
2.40E-01
(mg/kg-day)1
B2
IRIS
2/4/2008
4-4-DDE
3.40E-01
(mg/kg-day)1
1.00E+00
3.40E-01
(mg/kg-day)1
NA
IRIS
8/20/2012
A-BHC
6.30E+0Q
(mg/kg-day)1
1.00E+00
6.30E+00
(mg/kg-day)1
B2
IRIS
2/4/2008
ALDRIN
1.70E+01
(mg/kg-day)1
1.00E+00
1.70E+01
(mg/kg-day)1
B2
IRIS
2/4/2008
CHLORDANE
3.50E-01
(mg/kg-day)1
1.00E+00
3.50E-01
(mg/kg-day)1
B2
IRIS
4/29/2008
DIELDRIN
1.60E+01
(mg/kg-day)1
1.00E+00
1.60E+01
(mg/kg-day)1
B2
IRIS
2/4/2008
ENDOSULFAN II
NA
NA
NA
NA
NA
NA
NA
NA
Page 1 of 2
-------
Table 7-4
Cancer Toxicity Data - Oral/Dermal
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Oral Cancer
Slope Factor
Oral Absorption
Efficiency for Dermal
(Unitless)
(1)
Absorbed Cancer Slope Factor
for Dermal (2)
Weight of Evidence/ Cancer Guideline Description
(3)
Oral Cancer Slope Factor
Value
Units
Value
Units
Source(s)
Date(s)
(MM/DD/YYYY)
SVOCs
ACENAPHTHYLENE
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
BENZO(A)ANTHRACENE*
7.30E-01
(mg/kg-day)"1
8.90E-01
7.30E-01
(mg/kg-day)"1
B2, CSF derived according to USEPA 1993
IRIS
1/17/2008
BENZO(A)PYRENE
7.30E+00
(mg/kg-day)"1
8.90E-01
7.30E+00
(mg/kg-day)"1
B2
IRIS
1/17/2008
BENZO(B)FLUORANTHENE*
7.30E-01
(mg/kg-day)"1
8.90E-01
7.30E-01
(mg/kg-day)'1
B2
USEPA 1993 (STSC)
6/1/2003
BENZO(K)FLUORANTHENE*
7.30E-02
(mg/kg-day)"1
8.90E-01
7.30E-02
(mg/kg-day)"1
B2
USEPA 1993 (STSC)
6/1/2003
BIS(2-ETHYLHEXYL)PHTHALATE
1.40E-02
(mg/kg-day)'1
1.00E+00
1.40E-02
(mg/kg-day)'1
B2
IRIS
2/4/2008
CARBAZOLE
NA
NA
NA
NA
NA
NA
NA
NA
CHRYSENE
7.30E-03
(mg/kg-day)"1
8.90E-01
7.30E-03
(mg/kg-day)"1
B2
USEPA 1993 (STSC)
6/1/2003
DIBENZ(A,H)ANTHRACENE*
7.30E+00
(mg/kg-day)'1
8.90E-01
7.30E+00
(mg/kg-day)'1
B2
USEPA 1993 (STSC)
6/1/2003
DIBENZOFURAN
NA
NA
NA
NA
NA
D
IRIS
2/4/2008
INDENO(l,2,3-CD) PYRENE*
7.30E-01
(mg/kg-day)'1
8.90E-01
7.30E-01
(mg/kg-day)'1
B2
USEPA 1993 (STSC)
6/1/2003
NAPHTHALENE
NA
NA
NA
NA
NA
C
IRIS
2/4/2008
VOCs
1,2-DICHLOROBENZENE
NA
NA
NA
NA
NA
D
IRIS
8/22/2012
1,3-DICHLOROBENZENE
NA
NA
NA
NA
NA
D
IRIS
8/22/2012
1,4-DICHLOROBENZENE
5.40E-03
(mg/kg-day)"1
1.00E+00
5.40E-03
(mg/kg-day)'1
B2
CalEPA (STSC)
4/29/2008
CIS-1,2-DICHL0R0ETHYLENE
NA
NA
NA
NA
NA
NA
NA
NA
TRICHLOROETHYLENE
4.60E-02
(mg/kg-day)'1
1.00E+00
4.60E-02
(mg/kg-day)'1
A
IRIS
8/22/2012
Notes:
(1) Oral Absorption Efficiency from Exhibit 4-1 of USEPA (2004) RAGS Part E. For constituents not listed in Exhibit 4-1, an absorption efficiency of 1 is assumed. For constituents with a range of absorption efficiencies in Exhibit 4-1, the highest
value is reported.
(2) For Oral Absorption Efficiency for Dermal < 0.5, Absorbed CSF for Dermal = Oral CSF / Oral Absorption Efficiency for Dermal; otherwise, Absorbed CSF for Dermal = Oral CSF (USEPA 2004 RAGS Part E, Exhibit 4-1).
(3) Codes for Weight of Evidence: A - Human Carcinogen; B - Probable Human Carcinogen; C - Possible Human Carcinogen; D - Not Classifiable as to Human Carcinogenicity; E - Evidence of Non-Carcinogenicity in Humans.
* = For carcinogenic PAHs, relative potency approach with respect to benzo(a)pyrene applied to estimate Oral Cancer Slope Factor (see USEPA 1993 Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons,
EPA/600/R-93/089).
a = Oral and dermal CSFs for trivalent chromium utilized (hexavalent chromium not detected in any samples at site).
Sources:
Tier 1 - IRIS - United States Environmental Protection Agency (USEPA) Integrated Risk Information System (Available at: http://www.epa.gov/iris).
Tier 2 - PPRTV - USEPA Provisional Peer Reviewed Toxicity Values from the Office of Research and Development/National Center for Environmental Assessment/Superfund Health Risk Technical Support Center (STSC).
Tier 3 - Tox values approved by Superfund Technical Support Center. ATSDR - Agency for Toxic Substances and Disease Registry Minimal Risk Levels (MRLs, Available at: http://www.atsdr.cdc.gov/mrls/index.html); CALEPA - California
Environmental Protection Agency toxicity criteria database (Available at: http://www.0ehha.ca.g0v/risk/chemicalDB//index.asp); HEAST - USEPA Health Effects Assessment Summary Tables from the USEPA STSC; NCEA - National Center for
Environmental Assessment;USEPA (2003). Memo from Southerland. OSWER Directive 9285.7-75. USEPA (1993) Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons, EPA/600/R-93/089).
STSC - Indicates that the associated value was provided for this assessment by the Superfund Technical Support Center.
Page 2 of 2
-------
Table 7-5
Toxicity Data - Inhalation
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Inhalation Unit Risk
Weight of Evidence/
Cancer Guideline Description
(1)
Unit Risk: Inhalation
Cancer Slope Factor
Value
Units
Source(s)
Date(s)
(MM/DD/YYYY)
METALS
ALUMINUM
NA
NA
NA
NA
NA
ANTIMONY
NA
NA
NA
NA
NA
ARSENIC
4.30E+00
(mg/m3)1
A
IRIS
2/5/2008
BARIUM
NA
NA
D
IRIS
4/29/2008
CADMIUM
1.80E+00
(mg/mS)1
B1
IRIS
2/5/2008
CHROMIUM, TOTAL*'
NA
NA
D
IRIS
1/15/2010
COBALT
9.00E-03
(mg/mB)4
2B
PPRTV
10/23/2006
COPPER
NA
NA
D
IRIS
2/5/2008
IRON
NA
NA
NA
NA
NA
LEAD
NA
NA
B2
IRIS
11/3/2008
MANGANESE
NA
NA
D
IRIS
2/5/2008
MERCURY
NA
NA
D
IRIS
1/23/2008
NICKEL
2.6QE-01
(mg/m3)1
A
CalEPA (STSC)
4/29/2008
SELENIUM
NA
NA
D
IRIS
2/5/2008
SILVER
NA
NA
D
IRIS
2/5/2008
THALLIUM
NA
NA
D (thallium chloride)
IRIS
2/5/2008
VANADIUM
NA
NA
NA
NA
NA
ZINC
N A
NA
NA
NA
NA
PCBs
AROCLOR1248
5.70E-01
|mg/m3)1
No IRIS eval,, used upper bound PCBs (B2)
IRIS
2/5/2008
^^1^ ^3 ^— L^3 ^ 1
5.70E-01
(mg/m3)1
No IRIS eval., used upper bound PCBs (B2)
IRIS
2/5/2008
AROCLOR1260
S.70E-01
(mg/m3)4
No IRIS eval,, used upper bound PCBs |B2)
IRIS
2/5/2008
PESTICIDES
4,4-DDT
9.70E-02
(mg/m3)1
B2
IRIS
2/5/2008
4-4-DDD
6.90E-02
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
4-4-DDE
9.70E-02
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
A-BHC
1.80E+00
(mg/m3)1
B2
IRIS
2/5/2008
ALDRIN
4.90E+00
(mg/m3)1
B2
IRIS
2/5/2008
CHLORDANE
1.00E-01
(mg/m3)1
B2
IRIS
4/29/2008
DIELDRIN
4.60E+00
(mg/m3)1
B2
IRIS
2/5/2008
ENDOSULFAN II
NA
NA
NA
NA
NA
Page 1 of 2
-------
Table 7-5
Toxicity Data - Inhalation
Triangle Pacific Site
Elizabeth City, North Carolina
Chemical of
Potential Concern
Inhalation Unit Risk
Weight of Evidence/
Cancer Guideline Description
(1)
Unit Risk: Inhalation
Cancer Slope Factor
Value
Units
Source(s)
Date{s)
(MM/DD/YYYY)
SVOCs
ACENAPHTHYIENE
NA
NA
D
IRIS
2/5/2008
BENZO(A) ANTHRACENE
1.10E-01
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
BENZO(A)PYRENE
1.10E+00
(mg/m3)4
B2
CalEPA (STSC)
2/5/2008
BENZO(B)FLUORANTHENE
1.10E-01
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
BENZO(K)FLUORANTH EN E
1.10E-01
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
BIS(2-ETHYLHEXYL)PHTHALATE
2.40E-03
(mg/m3)4
B2
CalEPA (STSC)
2/5/2008
CARBAZOLE
NA
NA
NA
NA
NA
CHRYSENE
1.10E-02
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
DIBENZ(A,H)ANTHRACENE
1.20E+00
(mg/m3)1
B2
CalEPA (STSC)
2/5/2008
DIBENZOFURAN
NA
NA
D
IRIS
2/5/2008
INDENO[l,2,3-CD]PYRENE
1.10E-01
(mg/mS)1
B2
CalEPA (STSC)
2/5/2008
NAPHTHALENE
3.40E-02
(mg/m3)1
C
CalEPA (STSC)
4/29/2008
VOCs
1,2-DICHLOROBENZENE
NA
NA
D
IRIS
8/22/2012
1,3-DICHLOROBENZENE
NA
NA
D
IRIS
8/22/2012
1,4-DICHLOROBENZENE
1.10E-02
(mg/m3)1
B2
CalEPA (STSC)
4/29/2008
CIS-l(2-DICHLORO ETHYLENE
NA
NA
NA
NA
NA
TRICHLORO ETHYLENE
4.10E-03
(mg/m3)1
A
IRIS
8/22/2012
Notes:
(1) Codes for Weight of Evidence: A - Human Carcinogen; B - Probable Human Carcinogen; C- Possible Human Carcinogen; D - Not Classifiable as to Human Carcinogenicity; E - Evidence of Non~
Carcinogenicity in Humans, a = IUR fortrivalent chromium utilized (hexavalent chromium not detected in any samples at site),
NA - Not available
Sources;
Tier 1 - IRIS - United States Environmental Protection Agency (USEPA) Integrated Risk Information System (Available at: http://www.epa.gov/iris).
Tier 2 - PPRTV - USEPA Provisional Peer Reviewed Toxicity Values from the Office of Research and Development/National Center for Environmental Assessment/Superfund Health Risk Technical Support
Center, Tier 3 - Tox values approved by Superfund Technical Support Center, ATSDR - Agency for Toxic Substances and Disease Registry Minimal Risk Levels (MRLs, Available at:
http://www.atsdr,cdc.gov/mrls/index.html);
CALEPA - California Environmental Protection Agency toxicity criteria database (Available at: htp://www,oehha,ca.gov/risk/chemicalDB//indesf.asp); HEAST - USEPA Health Effects Assessment Summary
Tables from the USEPA STSC; NCEA - National Center for Environmental Assessment;USEPA (2003), Memo from Southerland, OSWER Directive 9285.7^75. USEPA (1993) Provisional Guidance for
Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons, EPA/6Q0/R 93/089).
STSC - Indicates that the associated value was provided for this assessment bythe Superfund Technical Support Center.
Page 2 of 2
-------
Table 7-6
Risk and Hazard Summary
Triangle Pacific Site
Elizabeth City, North Carolina
Timeframe
Receptor
Exposure Medium
Cancer Risk
RME
Cancer
Risk CTE
Non-Cancer
Hazards RME*
Non-Cancer
Hazards €11
Current/ Future
Child Fish
Fish Tissue
2xl0'5
3*10'6
1x100
SxlO'1
Consumer
All Media
2xl0*5
3xl0'6
1x100
SxlO'1
Current/ Future
Child Crab
Crab Tissue
IxlO'5
2xl0'6
1x100
6x10'
Consumer
All Media
IxlQ'5
2xl0"6
1x100
6xl0'1
Current/ Future
Older Child
Fish Tissue
2x10'-
3xlQ"6
1x100
3x10"'
Recreational Angler (Fish)
All Media
2x10'-
3xl0'6
1x100
3x10"'
Current/ Future
Older Child
Crab Tissue
2xl0'5
3*10"6
1x100
4x10"'
Recreational Angler (Crab)
All Media
2X1G*5
3xl0'6
1x100
4x10'1
Current/ Future
Adult Recreational
Fish Tissue
4x10 s
7xl0'6
1x100
3x10'
Angler (Fish)
All Media
4xl0'5
7xl0'6
1x100
3xl0'»
Current/ Future
Adult Recreational
Crab Tissue
4xl0'5
fixlO'6
1x100
3x10'
Angler (Crab)
All Media
4x10'-
6x10®
1x100
3xl0'1
Older Child
Swimmer
Surface Water
5xl0'7
2xlQ"8
SxlO'2
7xl0'3
Current/ Future
Surface Sediment
3x10'-
IxlO'5
IxlO'2
7xl0"3
All Media
3xl0'5
IxlO"5
6xl0'2
IxlO'2
Surface Water
fix 10'7
2xl0'8
3xl0'2
9x10J
Current/ Future
Adult Swimmer
Surface Sediment
3x10 s
7xl0'6
IxlO'2
7xl0"3
All Media
3xl0'5
7xl0~6
5xl0'2
2xl0"2
Surface/Subsurface Soil
3xl0'6
SxlO'7
5x10"'
SxlO'2
Future
Construction Worker
Outdoor Air
4x10'"
2x10"11
2x10 s
IxlO"5
Groundwater
1x10
2x10 7
7x10"'
2x10'"
All Media
4xl0'6
7xl0"?
1x100
3xl0'1
Surface/Subsurface Soil
8x10*
6x10 '
6x107
IxlO2
Current/Future
Utility/Sewer Line
Outdoor Air
IxlO'10
2x10 11
2xl0"6
IxlO6
Worker
Groundwater
3xl0'6
2xl0"7
7xl0"2
2xl02
All Media
IxlO'5
7xl0'7
1x10"'
3xl0'2
Surface Soil
8xl0'5
2xl0"5
4x10''
3xl0'»
Current/Future
Industrial Worker
Outdoor Air
2x10 9
9x10'10
7x10 5
6x10 5
All Media
8x10"-
2x105
4x10''
3x10 1
Page 1 of 2
-------
Table 7-6
Risk and Hazard Summary
Triangle Pacific Site
Elizabeth City, North Carolina
Timeframe
Receptor
Exposure Medium
Cancer Risk
RME
Cancer
Risk CTE
Non-Cancer
Hazards RME*
Non-Cancer
Hazards €11
Current/ Future
Adolescent T respasser
Surface Soil
6x10^
2*10'5
9x10''
1x10'1
All Media
6x10 5
2xl0"5
9x10"'
IxlO'1
Current/ Future
Adult Trespasser
Surface Soil
7x10 s
7x106
3x10 1
6x10/
All Media
7x10"-
7*106
3x10 1
6xl02
Notes;
* Non-cancer RME hazards shown for child fish and crab consumers are the highest His for effects to a specific target organ,
CTE - Central Tendency Exposure
RME - Reasonable Maximum Exposure
Page 2 of 2
-------
Table 7-7
Risk and Hazard Summary - Hypothetical Future Residential Scenario
Triangle Pacific Site
Elizabeth City, North Carolina
Timeframe
Receptor
Exposure Medium
Cancer Risk
RME
Cdnccr
Risk CTE
Non-Cancer
Hazards RME*
Non-Cancer
Hazards CTE
Future
Child
Resident
Surface Soil
1*103
5*10 4
lxlO1
6x10°
Outdoor Air
1x10"'
a
3x10
2x10"'
SxlO"3
Potable Water
2*10 J
4x10 4
SxlO1
3x10'
All Media
iKlQ2
4x10*
Current/Future
Adult
Resident
Surface Soil
3x10^
9x10 '
2x10°
1x10°
Outdoor Air
5x10"'
9*10"b
2x10"'
8xl0'3
Potable Water
3x10 J
§xl0~*
3X101
2x10'
Ail Media
4x10 J
1x10""
4x10*
2x10*
Notes:
Bold cells indicate values that exceed the cumulative threshold for acceptable cancer risk (1x10-4) or non-cancer hazard (1),
CTE - Central Tendency Exposure
RIME - Reasonable Maximum Exposure
Page 1 of 1
-------
Table 7-8a
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Terrestrial Exposure Area Surface Soil BERA Screening
Elizabeth City, North Carolina
CAS Number
Constituent of Potential Concern
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of
Max
Concentration
Detection
Frequency
Range of Detection
Limits3
(mg/kg)
Selected
Screening
Concentration"
(mg/kg)
USEPA Region 4,
Waste Management
Division Screening
Value for Hazardous
Waste Sitesc (mg/kg)
(Chronic)
USEPA Ecological
Soil Screening
Levels - Plantsd
(mg/kg)
USEPA Ecological
Soil Screening
Levels -
Invertebrates'1
(mg/kg)
USEPA Ecological
Soil Screening
Levels - Avesd
(mg/kg)
USEPA Ecological
Soil Screening
Levels - Mammals"
(mg/kg)
Selected
Criteria6
(mg/kg)
COCf
Rationale for
Selection or
Exclusion
METALS
7429-90-5
Aluminum
16247.14
28200.00
mg/kg
BH-14
21/21
-
2.82E+04
5.0E+01
NV
NV
NV
NV
5.0E+01
No
NBA
7440-36-0
Antimony
1.68
14.5 J
mg/kg
BH-18
16/19
0.0791-0.111
1.45E+01
3.5E+00
NV
7.8E+01
NV
2.7E-01
2.7E-01
Yes
ASL
7440-38-2
Arsenic
12.91
127 J
mg/kg
BH-18
19/21
1.8-2.5
1.27E+02
1.0E+01
1.8E+01
NV
4.3E+01
4.6E+01
1.0E+01
Yes
ASL/BAP
7440-39-3
Barium
152.59
710 J
mg/kg
BH-05
21/21
-
7.10E+02
1.7E+02
NV
3.3E+02
NV
2.0E+03
1.7E+02
Yes
ASL
7440-41-7
Beryllium
0.67
1.95 J
mg/kg
BH-05
21/21
0.25-0.25
1.95E+00
1.1E+00
NV
4.0E+01
NV
2.1E+01
1.1E+00
Yes
ASL
7440-43-9
Cadmium
4.77
60.6 J
mg/kg
BH-18
16/21
0.0471-0.44
6.06E+01
1.6E+00
3.2E+01
1.4E+02
7.7E-01
3.6E-01
3.6E-01
Yes
ASL/BAP
7440-70-2
Calcium
6679.00
29,500 J
mg/kg
BH-05
19/21
1410-1820
2.95E+04
NV
NV
NV
NV
NV
NV
No
NUT
7440-47-3
Chromium
36.94
250 J
mg/kg
BH-18
24/24
-
2.50E+02
4.0E-01
NV
NV
2.6E+01
3.4E+01
4.0E-01
Yes
ASL
7440-50-8
Copper
57.23
649.00
mg/kg
BH-18
21/21
-
6.49E+02
4.0E+01
7.0E+01
8.0E+01
2.8E+01
4.9E+01
2.8E+01
Yes
ASL/BAP
57-12-5
Cyanide
0.50
1.10
mg/kg
BH-05
7/17
0.2-0.25
1.10E+00
9.0E-01
NV
NV
NV
NV
9.0E-01
Yes
ASL
7439-89-6
Iron
29243.81
357000.00
mg/kg
BH-18
21/21
-
3.57E+05
2.0E+02
NV
NV
NV
NV
2.0E+02
Yes
ASL
7439-92-1
Lead
122.81
685.00
mg/kg
BH-18
21/21
-
6.85E+02
5.0E+01
1.2E+02
1.7E+03
1.1E+01
5.6E+01
1.1E+01
Yes
ASL/BAP
7439-95-4
Magnesium
1827.14
3550.00
mg/kg
BH-26
21/21
-
3.55E+03
NV
NV
NV
NV
NV
NV
No
NUT
7439-96-5
Manganese
250.44
1220.00
mg/kg
BH-05
21/21
-
1.22E+03
1.0E+02
2.2E+02
4.5E+02
4.3E+03
4.0E+03
1.0E+02
Yes
ASL
7439-97-6
Mercury
0.14
0.45
mg/kg
BH-05
21/21
-
4.49E-01
1.0E-01
NV
NV
NV
NV
1.0E-01
Yes
ASL
7440-02-0
Nickel
20.83
182 J
mg/kg
BH-18
21/21
-
1.82E+02
3.0E+01
3.8E+01
2.8E+02
2.1E+02
1.3E+02
3.0E+01
Yes
ASL/BAP
7440-09-7
Potassium
1159.00
2,510 J
mg/kg
BH-05
21/21
-
2.51 E+03
NV
NV
NV
NV
NV
NV
No
NUT
7782-49-2
Selenium
0.53
3.08
mg/kg
BH-05
19/21
0.35-0.39
3.08E+00
8.1E-01
5.2E-01
4.1E+00
1.2E+00
6.3E-01
5.2E-01
Yes
ASL/BAP
7440-22-4
Silver
0.34
2.92 J
mg/kg
BH-18
18/21
0.0234-0.23
2.92E+00
2.0E+00
5.6E+02
NV
4.2E+00
1.4E+01
2.0E+00
Yes
ASL/BAP
7440-23-5
Sodium
263.11
2860.00
mg/kg
BH-18
18/21
12.4-62.5
2.86E+03
NV
NV
NV
NV
NV
NV
No
NUT
7440-62-2
Vanadium
23.53
40.6 J
mg/kg
BH-14
21/21
-
4.06E+01
2.0E+00
NV
NV
7.8E+00
2.8E+02
2.0E+00
Yes
ASL
7440-66-6
Zinc
518.51
3570.00
mg/kg
BH-18
21/21
-
3.57E+03
5.0E+01
1.6E+02
1.2E+02
4.6E+01
7.9E+01
4.6E+01
Yes
ASL/BAP
PCBs
Total PCBs
10.29
110.00
mg/kg
BH-18
12/17
0.0037-3.3
1.10E+02
2.0E-02
NV
NV
NV
NV
2.0E-02
Yes
ASL/BAP
PESTICIDES
72-54-8
4-4-DDD
0.02
0.14 J
mg/kg
BH-26
21/21
0.00036-0.032
1.40E-01
2.5E-03
NV
NV
9.3E-02
2.1E-02
2.5E-03
Yes
ASL/BAP
72-55-9
4-4-DDE
0.34
2.60
mg/kg
BH-26
18/21
0.00036-0.0041
2.60E+00
2.5E-03
NV
NV
9.3E-02
2.1E-02
2.5E-03
Yes
ASL/BAP
50-29-3
4-4-DDT
0.73
5.50
mg/kg
BH-18
14/21
0.00036-0.093
5.50E+00
2.5E-03
NV
NV
9.3E-02
2.1E-02
2.5E-03
Yes
ASL
319-84-6
a-BHC
0.08
0.13
mg/kg
BH-18
2/19
0.00019-0.0097
1.30E-01
2.5E-03
NV
NV
NV
NV
2.5E-03
Yes
ASL/BAP
309-00-2
Aldrin
0.13
0.49 JN
mg/kg
BH-18
4/19
0.00019-0.034
4.90E-01
2.5E-03
NV
NV
NV
NV
2.5E-03
Yes
ASL/BAP
Constituents of Chlordane
0.12
1.2
mg/kg
BH-16
14/21
0.00096-0.38
1.20E+00
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
319-86-8
d-BHC
0.03
0.05
mg/kg
BH-18
2/21
0.00049-0.026
4.90E-02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
60-57-1
Dieldrin
0.02
0.067 JN
mg/kg
BH-05
3/21
0.00036-0.31
6.70E-02
5.0E-04
NV
NV
2.2E-02
4.9E-03
5.0E-04
Yes
ASL/BAP
959-98-8
Endosulfan I
0.12
0.31 J
mg/kg
BH-05
4/21
0.00025-0.013
3.10E-01
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
33213-65-9
Endosulfan II
0.00
0.00089 J
mg/kg
BH-24
2/19
0.00036-0.019
8.90E-04
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
1031-07-8
Endosulfan Sulfate
0.07
0.08
mg/kg
BH-05
6/21
0.00038-0.28
8.00E-02
NV
NV
NV
NV
NV
NV
Yes
NSC
72-20-8
Endrin
0.02
0.064 JN
mg/kg
BH-15
3/21
0.00036-4.1
6.40E-02
1.0E-03
NV
NV
NV
NV
1.0E-03
Yes
ASL/BAP
7421-93-4
Endrin Aldehyde
0.10
0.47
mg/kg
BH-18
5/21
0.00036-4.1
4.70E-01
NV
NV
NV
NV
NV
NV
Yes
NSC
76-44-8
Heptachlor
0.00
0.01 J
mg/kg
BH-26
4/21
0.00019-0.018
1.00E-02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
1024-57-3
Heptachlor Epoxide
0.00
0.0046 J
mg/kg
BH-05
4/21
0.00019-0.061
4.60E-03
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
58-89-9
Lindane
0.00
0.0098 J
mg/kg
BH-15
4/19
0.0002-0.0097
9.80E-03
5.0E-05
NV
NV
NV
NV
5.0E-05
Yes
ASL/BAP
72-43-5
Methoxychlor
0.43
1.20
mg/kg
BH-05
3/19
0.0019-0.097
1.20E+00
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
l:\Viacom-Triangle 10679\47733.Revisions-To-Ri\Docs\Reports\BERA\FALL 2014 Revision\Tables\Table 4-1 Surf Soil BERA ScreenRev3 xls
O'Brien & Gere
1 of 2
-------
Table 7-8a
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Terrestrial Exposure Area Surface Soil BERA Screening
Elizabeth City, North Carolina
CAS Number
Constituent of Potential Concern
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of
Max
Concentration
Detection
Frequency
Range of Detection
Limits3
(mg/kg)
Selected
Screening
Concentration"
(mg/kg)
USEPA Region 4,
Waste Management
Division Screening
Value for Hazardous
Waste Sitesc (mg/kg)
(Chronic)
USEPA Ecological
Soil Screening
Levels - Plantsd
(mg/kg)
USEPA Ecological
Soil Screening
Levels -
Invertebrates'1
(mg/kg)
USEPA Ecological
Soil Screening
Levels - Avesd
(mg/kg)
USEPA Ecological
Soil Screening
Levels - Mammals"
(mg/kg)
Selected
Criteria6
(mg/kg)
COCf
Rationale for
Selection or
Exclusion
SVOCs
98-86-2
Acetophenone
0.18
0.32 J
mg/kg
BH-18
2/15
0.018-1.3
3.20E-01
NV
NV
NV
NV
NV
NV
Yes
NSC
117-81-7
bis(2-Ethylhexyl) Phthalate
15.61
73.00
mg/kg
BH-14
15/17
0.074-0.078
7.30E+01
NV
NV
NV
NV
NV
NV
Yes
NSC
86-74-8
Carbazole
5.19
11.00
mg/kg
BH-05
5/17
0.018-0.49
1.10E+01
NV
NV
NV
NV
NV
NV
Yes
NSC
132-64-9
Dibenzofuran
3.52
12.00
mg/kg
BH-15
6/17
0.018-410
1.20E+01
NV
NV
NV
NV
NV
NV
Yes
NSC
117-84-0
di-n-Octyl Phthalate
2.68
5.1
mg/kg
BH-05
2/16
0.074-5.1
5.10E+00
NV
NV
NV
NV
NV
NV
Yes
NSC
108-95-2
Phenol
1.07
1.30
mg/kg
BH-19
2/15
0.018-1.3
1.30E+00
5.0E-02
NV
NV
NV
NV
5.0E-02
Yes
ASL/BAP
Low Molecular Weight PAHs1
28.26
246.47
mg/kg
BH-26
19/21
0.0008-0.41
2.46E+02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
High Molecular Weight PAHs2
57.88
765.00
mg/kg
BH-26
19/21
0.0037-410
7.65E+02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
VOCs
71-55-6
1,1,1-Trichloroethane
0.01
0.008 J
mg/kg
G-SS-1
2/17
0.001-0.005
8.00E-03
NV
NV
NV
NV
NV
NV
Yes
NSC
67-64-1
Acetone
0.01
0.38
mg/kg
BH-20
7/17
0.007-0.033
3.80E-01
NV
NV
NV
NV
NV
NV
No
LABCON
100-52-7
Benzaldehyde
0.68
1.70
mg/kg
BH-18
3/15
0.074-5.1
1.70E+00
NV
NV
NV
NV
NV
NV
Yes
NSC
98-82-8
Isopropylbenzene
0.09
0.091
mg/kg
BH-15
1/13
0.001-0.005
9.10E-02
NV
NV
NV
NV
NV
NV
Yes
NSC
127-18-4
Tetrachloroethene
0.01
0.02
mg/kg
G-SS-1
2/15
0.001-0.005
1.60E-02
1.0E-02
NV
NV
NV
NV
1.0E-02
Yes
ASL
79-01-6
Trichloroethylene
0.00
0.002
mg/kg
U-SS-1
1/17
0.001-11
2.00E-03
1.0E-03
NV
NV
NV
NV
1.0E-03
No
LDF
Notes:
Surface soil = includes samples collected from the 0-0.5 ft bgs and 0.5-1 ft bgs intervals as well as soil from the terrestrial exposure area where the depth of the sample was not specified.
BERA Screening = conducted for the purpose of selecting COCs. This series of screening tables contains all COPECs retained in the SLERA screening and applies additional rationale for retention or exclusion. The result is a refined list of COCs that are further evaluated in this BERA.
Compounds that are excluded in this screening step are not evaluated further.
Constituents of Chlordane includes all isomers detected.
a:= 100% detection frequency,
b: Maximum detected concentration.
c: Screening values are from » USEPA Region IV Ecological Screening Criteria, Waste Management Division Soil Screening Values for Hazardous Waste Sites (Chronic), Office of Technical Services (OTS) Supplemental Guidance to RAGS. November 1998.
d: Screening values are from USEPA 2003a.
e: Minimum of screening criteria.
f: Constituent selected or deleted from further evaluation. Compounds are selected as constituents of concern if the selected screening concentration is greater than the selected criteria or if there are no screening criteria available or if they are known to bioaccumulate.
1. Low Molecular Weight PAHs include acenapthene, acenaphthylene, anthracene, fluoranthene, fluorene, napthalene, and phenanthrene. Not all constituents may be present.
2. High Molecular Weight PAHs include benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, indeno(1,2,3-CD)pyrene, and pyrene. Not all constituents may be present.
ASL = Above Screening Level.
BAP = Bioaccumulation Potential. USEPA. 2000. Bioaccumulation Testing and Interpretation for the Purposes of Sediment Quality Assessment. United States Environmental Protection Agency. EPA 823-R-00-001. Bioaccumulation Analysis Workgroup.
http://www.epa.gov/waterscience/cs/biotesting/bioaccum.pdf. Washington, D.C. February 2000.
BSL = Below Screening Level.
COC = Constituent of Concern.
J = Estimated detect value.
JN = Indicates that there is presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions.
LABCON = Laboratory Contaminant.
LDF = Low Detection Frequency.
NBA = Not Biologically Available.
NSC = No Screening Criteria.
NUT = Nutrient.
NV = No Value.
PAH = Polyaromatic hydrocarbons.
l:\Viacom-Triangle 10679\47733.Revisions-To-Ri\Docs\Reports\BERA\FALL 2014 Revision\Tables\Table 4-1 Surf Soil BERA ScreenRev3 xls
O'Brien & Gere
2 of 2
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Table 7-8b
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Terrestrial Exposure Area Surface Water BERA Screening
Elizabeth City, North Carolina
CAS
Compound
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of
Maximum
Detected
Value
Detection
Frequency
Range of Non-
Detect Values3
Concentration
Used for
Screening
(ug/L)
USEPA Region 4,
Waste Management
Division Screening
Value for Hazardous
Waste Sitesc (ug/L)
(Chronic!
USEPA Region 3
BTAG Freshwater
Benchmarks
(ug/L)
NCDENR
Freshwater
Aquatic Life
Standards6 (ug/L)
National
Recommende
d Water
Quality
Criteria' (ug/L)
USEPA
EcoTOX
Screening
Criteria -
AWQC/Tier
II9 lualL)
Selected
Screening
Criteria'1
COC'
Rationale for
Selection or
Deletion
METALS
7429-90-5
Aluminum
1620.00
1620 J
ug/L
BH-19
1/1
-
1.62E+03
8.70E+01
8.70E+01
8.70E+01
8.70E+01
NV
8.70E+01
No
NBA
7440-38-2
Arsenic
13.60
13.60
ug/L
BH-19
1/1
-
1.36E+01
1.90E+02
5.00E+00
5.00E+01
NV
NV
5.00E+00
Yes
ASL/BAP
7440-39-3
Barium
222.00
222.00
ug/L
BH-19
1/1
-
2.22E+02
NV
4.00E+00
NV
NV
3.90E+00
3.90E+00
Yes
ASL
7440-43-9
Cadmium'
9.80
9.8 J
ug/L
BH-19
1/1
-
9.80E+00
2.44E+00
2.50E-01
2.00E+00
4.91 E-01
2.26E+00
2.50E-01
Yes
ASL/BAP
7440-48-4
Cobalt
6.60
6.6 J
ug/L
BH-19
1/1
-
6.60E+00
NV
2.30E+01
NV
NV
3.00E+00
3.00E+00
Yes
ASL
7440-50-8
Copper2
437.00
437 J
ug/L
BH-19
1/1
-
4.37E+02
2.77E+01
9.00E+00
7.00E+00
2.10E+01
2.66E+01
7.00E+00
Yes
ASL/BAP
7439-89-6
Iron
44500.00
44500.00
ug/L
BH-19
1/1
-
4.45E+04
1.00E+03
3.00E+02
1.00E+03
1.00E+03
1.00E+03
3.00E+02
Yes
ASL
7439-92-1
Lead3
401.00
401
ug/L
BH-19
1/1
-
4.01 E+02
1.13E+01
2.50E+00
2.50E+01
7.31 E+00
8.95E+00
2.50E+00
Yes
ASL/BAP
7439-96-5
Manganese
608.00
608
ug/L
BH-19
1/1
-
6.08E+02
NV
1.20E+02
NV
NV
8.00E+01
8.00E+01
Yes
ASL
7440-02-0
Nickel4
28.00
28 J
ug/L
BH-19
1/1
-
2.80E+01
3.66E+02
5.20E+01
8.80E+01
1.21 E+02
3.65E+02
5.20E+01
Yes
BSL/BAP
7782-49-2
Selenium
0.47
0.47 J
ug/L
BH-19
1/1
-
4.70E-01
5.00E+00
1.00E+00
5.00E+00
5.00E+00
5.00E+00
1.00E+00
Yes
BSL/BAP
7440-22-4
Silver
2.20
2.2
ug/L
BH-19
1/1
-
2.20E+00
1.20E-02
3.20E+00
6.00E-02
NV
NV
1.20E-02
Yes
ASL/BAP
7440-66-6
Zinc5
2090
2091 J
ug/L
BH-19
1/1
-
2.09E+03
2.47E+02
1.20E+02
5.00E+01
2.47E+02
2.43E+02
5.00E+01
Yes
ASL/BAP
PCBs
1336-36-3
Total PCBs6
0.20
0.2 J
ug/L
BH-19
1/1
0.098-0.2
2.00E-01
1.40E-02
7.40E-05
1.00E-03
1.40E-02
NV
7.40E-05
Yes
ASL/BAP
Pesticides
72-55-9
4-4-DDE
0.0091
0.0091 J
ug/L
BH-19
1/1
-
9.10E-03
1.05E+01
NV
NV
NV
NV
1.05E+01
Yes
BSL/BAP
50-29-3
4-4-DDT
0.018
0.018 J
ug/L
BH-19
1/1
-
1.80E-02
1.00E-03
5.00E-04
1.00E-03
NV
1.30E-02
5.00E-04
Yes
ASL/BAP
SVOCs
117-81-7
bis(2-Ethylhexyl) Phthalate
8.00
8
ug/L
BH-19
1/1
-
8.00E+00
3.00E-01
1.60E+01
NV
NV
3.20E+01
3.00E-01
Yes
ASL
Low Molecular Weight PAHs7
0.01
0.01
ug/L
BH-19
1/1
0.0096-0.029
1.10E-02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
High Molecular Weight PAHs8
0.02
0.02
ug/L
BH-19
1/1
0.0096-0.0096
2.30E-02
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
VOCs
156-59-2
cis-1,2-Dichloroethylene
8.00
8 J
ug/L
BH-19
1/1
-
8.00E+00
NV
NV
NV
NV
NV
NV
Yes
NSC
108-88-3
Toluene
9.00
9 J
ug/L
BH-19
1/1
-
9.00E+00
1.75E+02
2.00E+00
1.10E+01
NV
NV
2.00E+00
Yes
ASL
Notes:
BERA Screening = conducted for the purpose of selecting COCs. This series of screening tables contains all COPECs retained in the SLERA screening and applies additional rationale for retention or exclusion. The result is a
refined list of COCs that are further evaluated in this BERA. Compounds that are excluded in this screening step are not evaluated further.
Aluminum is not biologically available in surface water where pH exceeds 5.5; average surface water pH at the included sampling locations is approximately 7.69.
a: "_M = 100% detection frequency,
b: Maximum detected concentration.
c: Screening values are from USEPA Region IV Eco Screening Criteria, Waste Management Division Freshwater Surface Water Screening Values for Hazardous Waste Sites (Chronic), Office of
Technical Services (OTS) Supplemental Guidance to RAGS dated November 2001.
d: Screening values are from USEPA Region 3 BTAG Freshwater Benchmarks (2013), http://www.epa.gov/reg3hwmd/risk/eco/btag/sbv/fw/screenbench.htm.
e: Screening values are from the North Carolina Department of Environment and Natural Resources/EPA Surface Water Criteria table (May 2013),
http://portal.ncdenr.org/c/document_library/get_file?uuid=dfc89f23-a372-4782-b3b0-60e6884b1696&groupld=38364.
f: Screening values from USEPA National Recommended Water Quality Criteria: Freshwater Aquatic Life Criteria (2013), http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm.
g: Screening values are from Toxicological Benchmarks for Screening Potential Contaminants of Concern for Effects on Aquatic Biota: 1996 Revision (USEPA, 1996), http://rais.ornl.gov/documents/tm96r2.pdf.
h: Minimum of screening criteria.
i: Constituent selected or deleted from further evaluation. Compounds are selected as constituents of concern if the selected screening concentration is greater than the selected criteria.
1. USEPA Region 4 calculated using: exp(0.0.7825[ln(Hardness)-3.49). USEPA National Recommended Ambient Water Quality Criteria Freshwater calculated using: exp(0.7409[ln(hardness)]-4.719) x (1.101672- [ln(hardness)x(0.041838)]). USEPA EcoTOX criteria
calculated using: 0.909*EXP((0.7852*ln(hardness))-3.49).
2. USEPA Region 4 calculated using: exp(0.8545(ln(hardness)-1.465). USEPA National Recommended Ambient Water Quality Criteria Freshwater calculated using: 0.96*(exp(0.8545[ln(hardness)]-1.702). USEPA EcoTOX criteria
calculated using: 0.96*(exp((0.8545*ln(hardness))-1.465))*0.96.
3. USEPA Region 4 calculated using: exp(1.273[(ln(Hardness)]-4.705). USEPA National Recommended Ambient Water Quality Criteria Freshwater calculated using: [1.46203-[ln(hardness)(0.145712)]] exp(1.273[ln(hardness)]-4.705).
USEPA EcoTOX criteria calculated using: 0.791 *(exp((1.273*ln(hardness))-4.705)).
4. USEPA Region 4 calculated using: exp(0.846[(ln(Hardness)]+1.1645). USEPA National Recommended Ambient Water Quality Criteria Freshwater calculated using:(0.997) exp (0.8460[ln(hardness)]+0.0584). USEPA EcoTOX criteria
calculated using: 0.997*(exp((0.846*ln(hardness))+1.1645)).
5. USEPA Region 4 calculated using: exp(0.8473[(ln(Hardness)]+0.7614). USEPA National Recommended Ambient Water Quality Criteria Freshwater calculated using: (0.986)*exp(0.8473[ln(hardness)]+0.884). USEPA EcoTOX
criteria calculated using: (exp((0.8473*ln(hardness))+0.7614))*0.986.
6. USEPA Region 4, Waste Management Division Freshwater Screening Value for Aroclor 1254 utilized.
7. Low Molecular Weight PAHs include acenapthene, acenaphthylene, anthracene, fluoranthene, fluorene, napthalene, and phenanthrene. Not all constituents may be present.
8. High Molecular Weight PAHs include benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, indeno(1,2,3-CD)pyrene, and pyrene. Not all constituents may be present.
ASL = Above Screening Level.
BAP = Bioaccumulation Potential. USEPA. 2000. Bioaccumulation Testing and Interpretation for the Purposes of Sediment Quality Assessment. United States Environmental Protection Agency. EPA 823-R-00-001. NBA = Not biologically active.
Bioaccumulation Analysis Workgroup, http://www.epa.gov/waterscience/cs/biotesting/bioaccum.pdf. Washington, D.C. February 2000. NSC = No Screening Criteria.
BSL = Below Screening Level. NUT = Nutrient.
COC = Constituent of Concern. NV = No value was available.
J = Estimated detect value. PAH = Polyaromatic hydrocarbons.
l:\Viacom-Triangle.10679\47733.Revistons-To-RADocs\Reports\BERA\FALL 2014 Revision\Tables\Table 4-2 Site SW BERA Screen rev1 .xls
O'Brien & Gere
1 of 1
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Table 7-8c
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Aquatic Exposure Area Surface Water BERA Screening
Elizabeth City, North Carolina
CAS
Compound
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of
Maximum
Detected
Value
Detection
Frequency
Range of Non-Detect
Values3
Concentration
Used for
Screening1"
(ug/L)
USEPA Region 4, Waste
Management Division
Screening Value for
Hazardous Waste Sites0
(ug/L) (Chronic)
USEPA Region 3
BTAG Marine
Benchmarks'1
(ug/L)
NCDENR
Saltwater
Aquatic Life
Standards6
(ug/L)
National
Recommended
Water Quality
Criteria'
(ug/L)
(Chronic)
USEPA EcoTOX
Screening
Criteria -
AWQC/Tier II9
(ug/L)
Selected
Screening
Criteria11
COC1
Rationale for
Selection or
Deletion
METALS
7429-90-5
Aluminum
1080.00
1080.00
ug/L
PC-2-SW
1/9
200-200
1.08E+03
NV
NV
NV
NV
NV
NV
No
NBA
7440-38-2
Arsenic
2.11
3.7 J
ug/L
PC-11-SW
11/11
-
3.70E+00
NV
1.25E+01
5.00E+01
3.60E+01
NV
1.25E+01
Yes
BSL/BAP
7440-39-3
Barium
57.56
92.00
ug/L
PC-2-SW
9/9
-
9.20E+01
NV
NV
NV
NV
3.90E+00
3.90E+00
Yes
ASL
7440-70-2
Calcium
39288.89
43700.00
ug/L
PC-9-SW
9/9
-
4.37E+04
NV
NV
NV
NV
NV
NV
No
NUT
7440-50-8
Copper2
5.80
7.2 J
ug/L
PC-6-SW
3/9
4-4
7.20E+00
2.90E+00
3.10E+00
3.00E+00
3.10E+00
4.42E+01
2.90E+00
Yes
ASL/BAP
7439-89-6
Iron
1087.27
4980.00
ug/L
PC-2-SW
11/11
-
4.98E+03
NV
NV
NV
NV
1.00E+03
1.00E+03
Yes
ASL
7439-92-1
Lead3
2.65
2.80
ug/L
PC-2-SW
2/9
2-2
2.80E+00
8.50E+00
8.10E+00
2.50E+01
8.10E+00
2.41 E+01
8.10E+00
Yes
BSL/BAP
7439-95-4
Magnesium
89911.11
108000.00
ug/L
PC-9-SW
9/9
-
1.08E+05
NV
NV
NV
NV
NV
NV
No
NUT
7439-96-5
Manganese
317.78
667.00
ug/L
PC-2-SW
9/9
-
6.67E+02
NV
NV
NV
NV
8.00E+01
8.00E+01
Yes
ASL
7440-02-0
Nickel4
0.71
0.91 J
ug/L
PC-3
4/9
0.5-0.5
9.10E-01
8.30E+00
8.20E+00
8.30E+00
8.20E+00
1.91 E+01
8.20E+00
Yes
BSL/BAP
7440-09-7
Potassium
29744.44
35300.00
ug/L
PC-9-SW
9/9
-
3.53E+04
NV
NV
NV
NV
NV
NV
No
NUT
7440-23-5
Sodium
695222.22
839000.00
ug/L
PC-9-SW
9/9
-
8.39E+05
NV
NV
NV
NV
NV
NV
No
NUT
7440-66-6
Zinc5
6.96
11.2 J
ug/L
PC-2-SW
8/9
4-4
1.12E+01
8.60E+01
8.10E+01
8.60E+01
8.10E+01
4.02E+02
8.10E+01
Yes
BSL/BAP
SVOCs
118-74-1
Hexachlorobenzene
0.0035
0.0037 J
ug/L
PC-6-SW
3/18
0.0028-0.0098
9.80E-03
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
Low Molecular Weight PAHs6
0.04
0.08
ug/L
PC-3
4/9
0.0095-0.03
7.70E-02
NV
NV
NV
NV
NV
NV
Yes
NSC
High Molecular Weight PAHs7
0.08
0.15
ug/L
PC-6-SW
3/9
0.0095-0.1
1.48E-01
NV
NV
NV
NV
NV
NV
Yes
NSC
Notes:
BERA Screening = conducted for the purpose of selecting COCs. This series of screening tables contains all COPECs retained in the SLERA screening and applies additional rationale for retention or exclusion. The result is a
refined list of COCs that are further evaluated in this BERA. Compounds that are excluded in this screening step are not evaluated further.
a:= 100% detection frequency,
b: Maximum detected concentration.
c: Screening values are from USEPA Region IV Eco Screening Criteria, Waste Management Division Saltwater Surface Water Screening Values for Hazardous Waste Sites (Chronic), Office of
Technical Services (OTS) Supplemental Guidance to RAGS dated November 2001.
d: Screening values are from USEPA Region 3 BTAG Freshwater Benchmarks (2013), http://www.epa.gov/reg3hwmd/risk/eco/btag/sbv/fw/screenbench.htm.
e: Screening values are from the North Carolina Department of Environment and Natural Resources/EPA Surface Water Criteria table (May 2013),
http://portal.ncdenr.org/c/documentJibrary/get_file?uuid=dfc89f23-a372-4782-b3b0-60e6884b1696&groupld=38364.
f: Screening values from USEPA National Recommended Water Quality Criteria: Freshwater Aquatic Life Criteria (2013), http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm.
g: Screening values are from Toxicological Benchmarks for Screening Potential Contaminants of Concern for Effects on Aquatic Biota: 1996 Revision (USEPA, 1996), http://rais.ornl.gov/documents/tm96r2.pdf.
h: Minimum of screening criteria.
i: Constituent selected or deleted from further evaluation. Compounds are selected as constituents of concern if the selected screening concentration is greater than the selected criteria.
1. USEPA EcoTOX criteria calculated using 0.909*(exp((0.7852*LN(hardness))-3.49)).
2.USEPA EcoTOX criteria calculated using: 0.96*(exp((0.8545*ln(hardness))-1.465)).
3. USEPA EcoTOX criteria calculated using: 0.79r(exp((1.273*ln(hardness))-4.705)).
4. USEPA EcoTOX criteria calculated using: 0.997*(exp((0.846*ln(hardness))+1.1645)).
5. USEPA EcoTOX criteria calculated using: 0.986*(exp((0.8473*ln(hardness))+0.7614)).
6. Low Molecular Weight PAHs include acenapthene, acenaphthylene, anthracene, fluoranthene, fluorene, napthalene, and phenanthrene. Not all constituents may be present.
7. High Molecular Weight PAHs include benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, indeno(1,2,3-CD)pyrene, and pyrene. Not all constituents may be present.
ASL = Above Screening Level
BAP = Bioaccumulation Potential. USEPA. 2000. Bioaccumulation Testing and Interpretation for the Purposes of Sediment Quality Assessment. United States Environmental Protection Agency. EPA 823-R-00-001.
Bioaccumulation Analysis Workgroup, http://www.epa.gov/waterscience/cs/biotesting/bioaccum.pdf. Washington, D.C. February 2000.
BSL = Below Screening Level
COC = Constituent of Concern
J = Estimated detect value.
NBA = Not Biologically Available
NSC = No Screening Criteria
NUT = Nutrient
NV = No value was available
PAH = Polyaromatic hydrocarbons
l:\Viacom-Triangle.10679\47733.Revisions-To-Ri\Docs\Reports\BERA\FALL 2014 Revision\Tables\Table 4-3 Pailin Creek SW BERA Screen rev1.xls
O'Brien & Gere
1 of 1
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Table 7-8d
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Aquatic Exposure Area Sediment BERA Screening
Elizabeth City, North Carolina
USEPA Region 4,
CAS
Number
Constituent of Potential Concern
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of Max
Concentration
Detection
Frequency
Range of
Detection
Limits®
(mg/kg)
Selected
Screening
Concentration"
(mg/kg)
Waste Management
Division Screening
Value for Hazardous
Waste Sites0 (mg/kg)
(Chronic)
USEPA SQC
Valued
(Marine)
(mg/kg)
USEPA SQB
Valued
(mg/kg)
USEPA ERL
Valued 9
(mg/kg)
Selected
Criteria®
(mg/kg)
cocf
Rationale for
Selection or
Exclusion
METALS
7429-90-5
Aluminum
42877.80
77,900 J
mg/kg
PC-2-SD
9/9
-
7.79E+04
NV
NV
NV
NV
NV
No
NBA
7440-38-2
Arsenic
8.72
25.1 J
mg/kg
PC-2-SD
9/9
-
2.51 E+01
7.24E+00
NV
NV
8.20E+00
7.24E+00
Yes
ASL/BAP
7440-39-3
Banum
127.64
317 J
mg/kg
PC-2-SD
9/9
-
3.17E+02
NV
NV
NV
NV
NV
Yes
NSC
7440-41-7
Beryllium
1.00
1.55 J
mg/kg
PC-8-SD
9/9
-
1.55E+00
NV
NV
NV
NV
NV
Yes
NSC
7440-43-9
Cadmium
0.87
3.39
mg/kg
PC-6-SD
9/9
-
3.39E+00
1 00E+00
NV
NV
1 20E+00
1.00E+00
Yes
ASL/BAP
7440-70-2
Calcium
3471.10
4,840 J
mg/kg
PC-2-SD
9/9
-
4.84E+03
NV
NV
NV
NV
NV
No
NUT
7440-47-3
Chromium
63.11
257 J
mg/kg
PC-6-SD
12/12
-
2.57E+02
5.23E+01
NV
NV
8.10E+01
5.23E+01
Yes
ASL
7440-48-4
Cobalt
11.52
322
mg/kg
PC-6-SD
9/9
-
3.22E+01
NV
NV
NV
NV
NV
Yes
NSC
7440-50-8
Copper
30.29
57.4
mg/kg
PC-6-SD
9/9
-
5.74E+01
1.87E+01
NV
NV
3.40E+01
1 87E+01
Yes
ASL/BAP
7439-89-6
Iron
21477.78
31,300 J
mg/kg
PC-8-SD
9/9
-
3.13E+04
NV
NV
NV
NV
NV
Yes
NSC
7439-92-1
Lead
55.10
154 J
mg/kg
PC-6-SD
9/9
-
1.54E+02
3.02E+01
NV
NV
4.70E+01
3.02E+01
Yes
ASL/BAP
7439-95-4
Magnesium
4951.10
7,620 J
mg/kg
PC-8-SD
9/9
-
7.62E+03
NV
NV
NV
NV
NV
No
NUT
7439-96-5
Manganese
187.56
318 J
mg/kg
PC-8-SD
9/9
-
3.18E+02
NV
NV
NV
NV
NV
Yes
NSC
7439-97-6
Mercury
0.10
0.203 J
mg/kg
PC-8-SD
9/9
-
2.03E-01
1.30E-01
NV
NV
1.50E-01
1.30E-01
Yes
ASL
7440-02-0
Nickel
22.92
36.1 J
mg/kg
PC-2-SD
9/9
-
3.61 E+01
1.59E+01
NV
NV
2.10E+01
1.59E+01
Yes
ASL/BAP
7440-09-7
Potassium
2505.56
3,800 J
mg/kg
PC-2-SD
9/9
-
3.80E+03
NV
NV
NV
NV
NV
No
NUT
7782-49-2
Selenium
0.69
1.32 J
mg/kg
PC-2-SD
9/9
-
1.32E+00
NV
NV
NV
NV
NV
Yes
NSC/BAP
7440-22-4
Silver
0.35
1.26
mg/kg
PC-4
9/9
-
1.26E+00
2.00E+00
NV
NV
NV
2.00E+00
Yes
BSL/BAP
7440-23-5
Sodium
3848.89
7,140 J
mg/kg
PC-8-SD
9/9
-
7.14E+03
NV
NV
NV
NV
NV
No
NUT
7440-28-0
Thallium
0.41
0.937 J
mg/kg
PC-2-SD
9/9
-
9.37E-01
NV
NV
NV
NV
NV
Yes
NSC
7440-62-2
Vanadium
39.90
76.6 J
mg/kg
PC-2-SD
9/9
-
7.66E+01
NV
NV
NV
NV
NV
Yes
NSC
7440-66-6
Zinc
177.60
665
mg/kg
PC-6-SD
9/9
-
6.65E+02
1.24E+02
NV
NV
1.50E+02
1.24E+02
Yes
ASL/BAP
PCBs
1336-36-3
Total PCBs
0.56
0.56
mg/kg
PC-6-SD
1/9
0.011-0.059
5.60E-01
3.30E+01
NV
NV
2.30E-02
2.30E-02
Yes
ASL/BAP
PESTICIDES
72-54-8
4-4-DDD
0.03
0.062 J
mg/kg
PC-2-SD
6/9
0.012-0.021
6.20E-02
3.30E+00
NV
NV
NV
3.30E+00
Yes
BSL/BAP
72-55-9
4-4-DDE
0.05
0.16 J
mg/kg
PC-2-SD
8/9
0.11-0.11
1.60E-01
3.30E+00
NV
NV
NV
3.30E+00
Yes
BSL/BAP
50-29-3
4-4-DDT
0.17
1.1
mg/kg
PC-4
8/9
0.012-0.012
1.10E+00
3.30E+00
NV
NV
1.60E-03
1.60E-03
Yes
ASL/BAP
309-00-2
Aldrin
0.041
0.072 J
mg/kg
PC-1-SD
8/9
0.011-0.011
7.20E-02
NV
NV
NV
NV
NV
Yes
NSC/BAP
Constituents of Chlordane
0.01
0.028 JN
mg/kg
PC-6-SD
5/9
0.0011-0.025
2.80E-02
NV
NV
NV
NV
NV
Yes
NSC/BAP
60-57-1
Dieldrin
0.11
0.26
mg/kg
PC-4
3/9
0.0022-0.035
2.60E-01
3.30E+00
9.50E-02
NV
NV
9.50E-02
Yes
ASL/BAP
1031-07-8
Endosulfan Sulfate
0.02
0.024 J
mg/kg
PC-6-SD
1/9
0.0022-0.11
2.40E-02
NV
NV
NV
NV
NV
Yes
NSC
72-20-8
Endrin
0.00
0.0042 J
mg/kg
PC-9-SD
1/9
0.0022-0.059
4.20E-03
3.30E+00
3.50E-03
NV
NV
3.50E-03
Yes
ASL/BAP
7421-93-4
Endrin Aldehyde
0.02
0.069 J
mg/kg
PC-5-SD
5/9
0.004-0.021
6.90E-03
NV
NV
NV
NV
NV
Yes
NSC
76-44-8
Heptachlor
0.01
0.013 JN
mg/kg
PC-9-SD
2/9
0.0021-0.054
1.30E-02
NV
NV
NV
NV
NV
Yes
NSC/BAP
1024-57-3
Heptachlor Epoxide
0.03
0.058 J
mg/kg
PC-9-SD
7/9
0.0059-0.011
5.80E-02
NV
NV
NV
NV
NV
Yes
NSC/BAP
58-89-9
Lindane
0.01
0.026 JN
mg/kg
PC-6-SD
2/9
0.0021-0.029
2.60E-02
3.30E+00
NV
NV
NV
3.30E+00
Yes
BSL/BAP
72-43-5
Methoxychlor
0.02
0.018 J
mg/kg
PC-9-SD
1/9
0.011-0.11
1.80E-02
NV
NV
1.90E-02
NV
1.90E-02
Yes
BSL/BAP
SVOCS
132-64-9
Dibenzofuran1
1.73
2.8
mg/kg
PC-6-SD
2/9
0.11-0.21
2.80E+00
3.30E+02
NV
2.00E+00
NV
2.00E+00
Yes
ASL
Low Molecular Weight PAHs1,2
22.29
133.42
mg/kg
PC-6-SD
7/9
0.006-0.042
1.33E+02
3.30E+02
NV
NV
NV
3.30E+02
Yes
BSL/BAP
High Molecular Weight PAHs3
21.38
153.40
mg/kg
PC-6-SD
9/9
-
1.53E+02
6.55E+02
NV
NV
NV
6.55E+02
Yes
BSL/BAP
VOCS
95-50-1
1,2-Dichlorobenzene
0.014
0.014
mg/kg
PC-6-SD
1/2
0.004-0.004
1.40E-02
NV
NV
3.40E-01
NV
3.40E-01
Yes
BSL/BAP
541-73-1
1,3-Dichlorobenzene
0.00
0.003 J
mg/kg
PC-6-SD
1/2
0.004-0.004
3.00E-03
NV
NV
1 70E+00
NV
1.70E+00
Yes
BSL/BAP
106-46-7
1,4-Dichlorobenzene
0.011
0.011
mg/kg
PC-6-SD
1/2
0.004-0.004
1.10E-02
NV
NV
3.50E-01
NV
3.50E-01
Yes
BSL/BAP
78-93-3
2-Butanone
0.03
0.046 J
mg/kg
PC-2-SD
4/9
0.008-0.024
4.60E-02
NV
NV
NV
NV
NV
No
LABCON
67-64-1
Acetone
0.08
0.19 J
mg/kg
PC-2-SD
9/9
-
1.90E-01
NV
NV
NV
NV
NV
No
LABCON
100-52-7
Benzaldehyde
0.59
0.59 J
mg/kg
PC-1-SD
1/9
0.27-0.83
5.90E-01
NV
NV
NV
NV
NV
Yes
NSC
75-15-0
Carbon Disulfide
0.00
0.004 UJ
mg/kg
PC-9-SD, PC-7-
SD.PC-3
1/9
0.002-0.006
4.00E-03
NV
NV
NV
NV
NV
Yes
NSC
108-90-7
Chlorobenzene
5.40
5.4
mg/kg
PC-6-SD
1/9
0.003-0.006
5.40E+00
NV
NV
8.20E-01
NV
8.20E-01
Yes
ASL
110-82-7
Cyclohexane
0.00
0.002 J
mg/kg
PC-6-SD
1/9
0.003-0.006
2.00E-03
NV
NV
NV
NV
NV
Yes
NSC
75-65-0
tert-ButylAlcohol
0.14
0.14 J
mg/kg
PC-2-SD
1/6
0.04-0.074
1.40E-01
NV
NV
NV
NV
NV
Yes
NSC
Notes:
Sediment = includes samples collected from the 0-0.5 ft bgs interval.
BERA Screening = conducted for the purpose of selecting COCs. This series of screening tables contains all COPECs retained in the SLERA screening and applies additional rationale for retention or exclusion. The result is a refined list of COCs that are
further evaluated in this BERA. Compounds that are excluded in this screening step are not evaluated further,
a: = 100% detection frequency,
b: Maximum detected concentration.
c: Screening values are from USEPA Region IV Eco Screening Criteria, Waste Management Division Sediment Screening Values for Hazardous Waste Sites (Chronic), Office of Technical Services (OTS) Supplemental Guidance to RAGS dated 2001
d: Screening values are from USEPA Office of Solid Waste and Emergency Response ECO Update, Vol. 6, No. 2 January 1996.
e: Minimum of screening criteria,
f: Constituent selected or deleted from further evaluation.
1. USEPA Region 4 criteria for low molecular weight PAHs utlized.
2. Low Molecular Weight PAHs include acenapthene, acenaphthylene, anthracene, fluoranthene, fluorene, napthalene, and phenanthrene. Not all constituents may be present.
3. High Molecular Weight PAHs include benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, indeno(1,2,3-CD)pyrene, and pyrene. Not all constituents may be present.
ASL = Above Screening Level.
BAP = Bioaccumulation Potential. USEPA. 2000. Bioaccumulation Testing and Interpretation for the Purposes of Sediment Quality Assessment. United States Environmental Protection Agency. EPA 823-R-00-001.
Bioaccumulation Analysis Workgroup, http://www.epa.gov/waterscience/cs/biotesting/bioaccum.pdf. Washington, D.C. February 2000
BSL = Below Screening Level. NBA = Not Biologically Available.
COC = Constituent of Concern. NSC = No Screening Criteria.
J = Estimated detect value. NUT = Nutrient.
JN = Indicates that there is presumptive evidence that the analyte is present, but it has not been confirmed due to column confirmation excursions. NV = No Value.
LABCON = Laboratory Contaminant. PAH = Polyaromatic hydrocarbons.
l:\ViaconvTriangle 10679VI7733.Revjsions-To-Ri\Docs\Reports\BERA\FALL 2014 RevisronVTabJesVTabte 4-4 PailinCreek Sed BERA Screen revl xls
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Table 7-8e
Former Triangle-Pacific Corporation Site
Baseline Ecological Risk Assessment
Shallow Groundwater BERA Screening
Elizabeth City, North Carolina
CAS
Compound
Average
Detected
Concentration
Maximum
Detected
Concentration
Unit
Location of
Maximum
Detected
Value
Detection
Frequency
Range of Non-
Detect Values3
Concentration
Used for
Screening"
(ug/L)
USEPA Region 4,
Waste Management
Division Screening
Value for Hazardous
Waste Sites0 (ug/L)
(Chronic)
USEPA Region 3
BTAG Freshwater
Benchmarks'1
(ug/L)
NCDENR
Freshwater Aquatic
Life Standards6
(ug/L)
National
Recommended Water
Quality Criteria'
(ug/L)
(Chronic)
USEPA EcoTOX
Screening
Criteria -
AWQC/Tier II9
(ug/L)
Selected
Screening
Criteria"
COC'
Rationale for
Selection or
Deletion
METALS
7440-38-2
Arsenic1
154.26
286.00
ug/L
MW-11
6/7
0.95-0.95
2.86E+02
1.90E+02
5.00E+00
5.00E+01
NV
1.90 E+02
5.00E+00
Yes
ASL/BAP
7440-39-3
Barium
139.63
237.00
ug/L
MW-5
6/6
-
2.37E+02
NV
4.00E+00
NV
NV
3.90E+00
3.90E+00
Yes
ASL
7440-70-2
Calcium
107683.30
123000 J
ug/L
MW-12
6/6
-
1.23E+05
NV
1.16E+05
NV
NV
NV
1.16E+05
No
NUT
7440-50-8
Copper3
0.57
0.63 J
ug/L
MW-5
4/6
0.38-0.38
6.30E-01
4.18E+01
9.00E+00
7.00E+00
NV
4.02E+01
7.00E+00
Yes
BSL/BAP
7439-89-6
Iron
55236.67
96600.00
ug/L
MW-11
6/6
-
9.66E+04
1.00E+03
3.00E+02
1.00E+03
1.00E+03
1.00E+03
3.00E+02
Yes
ASL
7439-92-1
Lead4
0.15
0.21 J
ug/L
MW-12
6/6
-
2.10E-01
2.09E+01
2.50E+00
2.50E+01
2.50E+00
1.65E+01
2.50E+00
Yes
BSL/BAP
7439-96-5
Manganese
660.50
1390.00
ug/L
MW-5
6/6
-
1.39E+03
NV
1.20E+02
NV
NV
8.00E+01
8.00E+01
Yes
ASL
7439-97-6
Mercury
0.03
0.034 J
ug/L
MW-11
1/6
0.026-0.026
3.40E-02
1.20E-02
2.60E-02
1.20E-02
NV
1.30E+00
1.20E-02
Yes
ASL
7440-02-0
Nickel5
1.36
1.7 J
ug/L
MW-12
5/6
0.5-0.5
1.70E+00
5.51 E+02
5.20E+01
8.80E+01
5.20E+01
5.49E+02
5.20E+01
Yes
BSL/BAP
7440-66-6
Zinc6
8.18
15.3 J
ug/L
MW-12
6/6
-
1.53E+01
3.71 E+02
1.20E+02
5.00E+01
1.20E+02
3.66E+02
5.00E+01
Yes
BSL/BAP
PESTICIDES
72-54-8
4-4-DDD
0.01
0.0055 J
ug/L
MW-11
1/6
0.0047-0.0048
5.50E-03
1.00E-03
1.10E-02
NV
1.00E-03
NV
1.00E-03
Yes
ASL/BAP
Constituents of Chlordane7
0.00
0.0031 J
ug/L
MW-5
1/6
0.0019-0.15
3.10E-03
4.30E-03
2.20E-03
4.00E-03
4.30E-03
1.70E-01
2.20E-03
Yes
ASL/BAP
1024-57-3
Heptachlor Epoxide8
0.00
0.0025 J
ug/L
MW-12
1/6
0.0022-0.0022
2.50E-03
3.80E-03
1.90E-03
NV
3.80E-03
6.90E-03
1.90E-03
Yes
ASL/BAP
SVOCs
Low Molecular Weight PAHs9
0.18
0.35
ug/L
MW-12
5/6
0.0095-0.029
3.54E-01
NV
NV
NV
NV
NV
NV
Yes
NSC/BAP
Notes:
a: = 100% detection frequency,
b: Maximum detected concentration.
c: Screening values are from USEPA Region IV Eco Screening Criteria, Waste Management Division Freshwater Surface Water Screening Values for Hazardous Waste Sites (Chronic), Office of Technical Services (OTS) Supplemental Guidance to RAGS dated November 2001.
d: Screening values are from USEPA Region 3 BTAG Freshwater Benchmarks (2013), http://www.epa.gov/reg3hwmd/risk/eco/btag/sbv/fw/screenbench.htm.
e: Screening values are from the North Carolina Department of Environment and Natural Resources/EPA Surface Water Criteria table (May 2013), http://portal.ncdenr.org/c/document_library/get_file?uuid=dfc89f23-a372-4782-b3b0-60e6884b1696&groupld=38364.
f: Screening values from USEPA National Recommended Water Quality Criteria: Freshwater Aquatic Life Criteria (2013), http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm.
g: Screening values are from Toxicological Benchmarks for Screening Potential Contaminants of Concern for Effects on Aquatic Biota: 1996 Revision (USEPA, 1996), http://rais.ornl.gov/documents/tm96r2.pdf.
h: Minimum of screening criteria.
i: Constituent selected or deleted from further evaluation. Compounds are selected as constituents of concern if the selected screening concentration is greater than the selected criteria.
1. Value for Arsenic ill was used for USEPA EcoTOX screening criteria source.
2. USEPA Region 4 value calculated using: exp(0.7825*LN(hardness)-3.49). USEPA EcoTOX criteria calculated using 0.909*exp((0.7852*LN(hardness))-3.49).
3. USEPA Region 4 value calculated using: exp(0.8545*LN(hardness)-1.465). USEPA EcoTOX criteria calculated using: 0.96*(exp((0.8545*ln(hardness))-1.465)).
4. USEPA Region 4 value calculated using: exp(1.273*LN(hardness)-4.705). USEPA EcoTOX criteria calculated using: 0.791*(exp((1.273*ln(hardness))-4.705)).
.5.USEPA Region 4 value calculated using: exp(0.846*LN(hardness)+1.1645). USEPA EcoTOX criteria calculated using: 0.997*(exp((0.846*ln(hardness))+1.1645)).
6. USEPA Region 4 value calculated using: exp(0.8473*LN(hardness)+0.7614). USEPA EcoTOX criteria calculated using: (exp((0.8473*ln(hardness))+0.7614))*0.986.
7. Values for chlordane were used for USEPA Region 3, NCDENR, and NRWQC screening criteria sources.
8. Values for heptachlor were used for NCDENR and NRWQC screening criteria sources.
9. Low Molecular Weight PAHs include acenapthene, acenaphthylene, anthracene, fluoranthene, fluorene, napthalene, and phenanthrene. Not all constituents may be present.
ASL = Above Screening Level.
BAP = Bioaccumulation Potential. USEPA. 2000. Bioaccumulation Testing and Interpretation for the Purposes of Sediment Quality Assessment. United States Environmental Protection Agency. EPA 823-R-00-001.
Bioaccumulation Analysis Workgroup, http://www.epa.gov/waterscience/cs/biotesting/bioaccum.pdf. Washington, D.C. February 2000.
BSL= Below Screening Level.
COC = Constituent of Concern.
J = Estimated detect value.
NSC = No Screening Criteria.
NUT = Nutrient.
NV = No value was available.
PAH = Polyaromatic hydrocarbons.
l:\Viacom-Triangle.10679V47733.Revisions-To-Ri\Docs\Reports\BERA\FALL2014 Revision\Tables\Table 4-5 Site GW BERA Screen revlxls
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Table 7-9
Terrestrial Exposure Area Surface Soil and Surface Water Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential
UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale*3
SURFACE SOIL
METALS
7440-36-0
Antimony
mg/kg
1.7E+00
1.5E+01
6.3E+00
6.3E+00
mg/kg
% UCL
99% KM (Chebyshev) UCL
7440-38-2
Arsenic
mg/kg
1.3E+01
1.3E+02
3.8E+01
3.8E+01
mg/kg
% UCL
95% KM (Chebyshev) UCL
7440-39-3
Barium
mg/kg
1.5E+02
7.1E+02
2.2E+02
2.2E+02
mg/kg
% UCL
95% H-UCL
7440-41-7
Beryllium
mg/kg
6.7E-01
2.0E+00
8.9E-01
8.9E-01
mg/kg
% UCL
95% Gamma UCL
7440-43-9
Cadmium
mg/kg
4.8E+00
6.1E+01
3.2E+01
3.2E+01
mg/kg
% UCL
95% KM (Chebyshev) UCL
7440-47-3
Chromium
mg/kg
3.7E+01
2.5E+02
4.9E+01
4.9E+01
mg/kg
% UCL
95% H-UCL
7440-50-8
Copper
mg/kg
5.7E+01
6.5E+02
1.9E+02
1.9E+02
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
57-12-5
Cyanide
mg/kg
5.0E-01
1.1E+00
4.4E-01
4.4E-01
mg/kg
% UCL
95% KM (t) UCL
7439-89-6
Iron
mg/kg
2.9E+04
3.6E+05
1.0E+05
1.0E+05
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
7439-92-1
Lead
mg/kg
1.2E+02
6.9E+02
3.0E+02
3.0E+02
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
7439-96-5
Manganese
mg/kg
2.5E+02
1.2E+03
5.5E+02
5.5E+02
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
7439-97-6
Mercury
mg/kg
1.4E-01
4.5E-01
2.6E-01
2.6E-01
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
7440-02-0
Nickel
mg/kg
2.1E+01
1.8E+02
5.6E+01
5.6E+01
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
7782-49-2
Selenium
mg/kg
5.3E-01
3.1E+00
1.1E+00
1.1E+00
mg/kg
% UCL
95% KM (Chebyshev) UCL
7440-22-4
Silver
mg/kg
3.4E-01
2.9E+00
1.8E+00
1.8E+00
mg/kg
% UCL
95% KM (Chebyshev) UCL
7440-62-2
Vanadium
mg/kg
2.4E+01
4.1E+01
2.7E+01
2.7E+01
mg/kg
% UCL
95% Student's-t UCL
7440-66-6
Zinc
mg/kg
5.2E+02
3.6E+03
1.4E+03
1.4E+03
mg/kg
% UCL
99% Chebyshev (Mean, Sd) UCL
PCBs
Total PCBs
mg/kg
1.0E+01
1.1E+02
1.0E+02
1.0E+02
mg/kg
% UCL
99% KM (Chebyshev) UCL
PESTICIDES
72-54-8
4-4-DDD
mg/kg
2.4E-02
1.4E-01
5.9E-02
5.9E-02
mg/kg
% UCL
97.5% KM (Chebyshev) UCL
72-55-9
4-4-DDE
mg/kg
3.4E-01
2.6E+00
9.3E-01
9.3E-01
mg/kg
% UCL
95% KM (Chebyshev) UCL
50-29-3
4-4-DDT
mg/kg
7.3E-01
5.5E+00
3.6E+00
3.6E+00
mg/kg
% UCL
99% KM (Chebyshev) UCL
319-84-6
a-BHC
mg/kg
7.5E-02
1.3E-01
NA
1.3E-01
mg/kg
Max
Maximum Detected Value
309-00-2
Aldrin
mg/kg
1.3E-01
4.9E-01
7.8E-02
7.8E-02
mg/kg
% UCL
95% KM (t) UCL
Constituents of Chlordane
mg/kg
6.0E-03
6.0E-03
6.8E-01
6.0E-03
mg/kg
Max
99% KM (Chebyshev) UCL
319-86-8
d-BHC
mg/kg
2.6E-02
4.9E-02
2.3E-02
2.3E-02
mg/kg
% UCL
97.5% KM (Chebyshev) UCL
60-57-1
Dieldrin
mg/kg
2.5E-02
6.7E-02
1.2E-02
1.2E-02
mg/kg
% UCL
95% KM (t) UCL
959-98-8
Endosulfan 1
mg/kg
1.2E-01
3.1E-01
5.5E-02
5.5E-02
mg/kg
% UCL
95% KM (t) UCL
33213-65-9
Endosulfan II
mg/kg
8.4E-04
8.9E-04
5.8E-04
5.8E-04
mg/kg
% UCL
95% KM (t) UCL
1031-07-8
Endosulfan Sulfate
mg/kg
7.3E-02
8.0E-02
1.7E-02
1.7E-02
mg/kg
% UCL
95% KM (t) UCL
72-20-8
Endrin
mg/kg
2.3E-02
6.4E-02
1.1E-02
1.1E-02
mg/kg
% UCL
95% KM (t) UCL
7421-93-4
Endrin Aldehyde
mg/kg
9.7E-02
4.7E-01
2.9E-01
2.9E-01
mg/kg
% UCL
99% KM (Chebyshev) UCL
76-44-8
Heptachlor
mg/kg
3.0E-03
1.0E-02
1.8E-03
1.8E-03
mg/kg
% UCL
95% KM (t) UCL
Page 1 of 3
-------
Table 7-9
Terrestrial Exposure Area Surface Soil and Surface Water Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential
UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale*3
1024-57-3
Heptachlor Epoxide
mg/kg
2.0E-03
4.6E-03
1.2E-03
1.2E-03
mg/kg
% UCL
95% KM (t) UCL
58-89-9
Lindane
mg/kg
4.5E-03
9.8E-03
2.4E-03
2.4E-03
mg/kg
% UCL
95% KM (t) UCL
72-43-5
Methoxychlor
mg/kg
4.3E-01
1.2E+00
2.0E-01
2.0E-01
mg/kg
% UCL
95% KM (t) UCL
SVOCs
98-86-2
Acetophenone
mg/kg
1.8E-01
3.2E-01
NA
3.2E-01
mg/kg
Max
Maximum Detected Value
117-81-7
bis(2-Ethylhexyl)Phthalate
mg/kg
1.6E+01
7.3E+01
3.9E+01
3.9E+01
mg/kg
% UCL
95% KM (Chebyshev) UCL
86-74-8
Carbazole
mg/kg
5.2E+00
1.1E+01
3.2E+00
3.2E+00
mg/kg
% UCL
95% KM (t) UCL
132-64-9
Dibenzofuran
mg/kg
3.5E+00
1.2E+01
3.0E+00
3.0E+00
mg/kg
% UCL
95% KM (t) UCL
117-84-0
di-n-OctylPhthalate
mg/kg
2.7E+00
5.1E+00
4.7E+00
4.7E+00
mg/kg
% UCL
99% KM (Chebyshev) UCL
108-95-2
Phenol
mg/kg
1.1E+00
1.3E+00
4.0E-01
4.0E-01
mg/kg
% UCL
95% KM (t) UCL
Low Molecular Weight PAHs
mg/kg
2.8E+01
2.5E+02
1.6E+02
1.6E+02
mg/kg
% UCL
99% KM (Chebyshev) UCL
High Molecular Weight PAHs
mg/kg
5.8E+01
7.7E+02
4.3E+02
4.3E+02
mg/kg
% UCL
99% KM (Chebyshev) UCL
VOCs
71-55-6
1,1,1-Trichloroethane
mg/kg
7.5E-03
8.0E-03
3.0E-03
3.0E-03
mg/kg
% UCL
95% KM (t) UCL
100-52-7
Benzaldehyde
mg/kg
6.8E-01
1.7E+00
5.5E-01
5.5E-01
mg/kg
% UCL
95% KM (t) UCL
98-82-8
Isopropylbenzene
mg/kg
9.1E-02
9.1E-02
NA
9.1E-02
mg/kg
Max
Maximum Detected Value
127-18-4
Tetrachloroethene
mg/kg
1.0E-02
1.6E-02
4.6E-03
4.6E-03
mg/kg
% UCL
95% KM (t) UCL
SURFACE WATER
METALS
7440-38-2
Arsenic
Pg/L
1.4E+01
1.4E+01
NA
1.4E-02
mg/L
Max
Maximum Detected Concentration
7440-39-3
Barium
Pg/L
2.2E+02
2.2E+02
NA
2.2E-01
mg/L
Max
Maximum Detected Concentration
7440-43-9
Cadmium
Pg/L
9.8E+00
9.8E+00
NA
9.8E-03
mg/L
Max
Maximum Detected Concentration
7440-48-4
Cobalt
Pg/L
6.6E+00
6.6E+00
NA
6.6E-03
mg/L
Max
Maximum Detected Concentration
7440-50-8
Copper
Pg/L
4.4E+02
4.4E+02
NA
4.4E-01
mg/L
Max
Maximum Detected Concentration
7439-89-6
Iron
Pg/L
4.5E+04
4.5E+04
NA
4.5E+01
mg/L
Max
Maximum Detected Concentration
7439-92-1
Lead
Pg/L
4.0E+02
4.0E+02
NA
4.0E-01
mg/L
Max
Maximum Detected Concentration
7439-96-5
Manganese
Pg/L
6.1E+02
6.1E+02
NA
6.1E-01
mg/L
Max
Maximum Detected Concentration
7440-02-0
Nickel
Pg/L
2.8E+01
2.8E+01
NA
2.8E-02
mg/L
Max
Maximum Detected Concentration
7782-49-2
Selenium
Pg/L
4.7E-01
4.7E-01
NA
4.7E-04
mg/L
Max
Maximum Detected Concentration
7440-22-4
Silver
Pg/L
2.2E+00
2.2E+00
NA
2.2E-03
mg/L
Max
Maximum Detected Concentration
7440-66-6
Zinc
Pg/L
2.1E+03
2.1E+03
NA
2.1E+00
mg/L
Max
Maximum Detected Concentration
PCBs
Total PCBs
Pg/L
2.0E-01
2.0E-01
NA
2.0E-04
mg/L
Max
Maximum Detected Concentration
PESTICIDES
72-55-9
4-4-DDE
Pg/L
9.1E-03
9.1E-03
NA
9.1E-06
mg/L
Max
Maximum Detected Concentration
50-29-3
4-4-DDT
Pg/L
1.8E-02
1.8E-02
NA
1.8E-05
mg/L
Max
Maximum Detected Concentration
Page 2 of 3
-------
Table 7-9
Terrestrial Exposure Area Surface Soil and Surface Water Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential
UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale!3
SVOCs
117-81-7
Bis(2-Ethylhexyl) Phthalate
^g/L
8.0E+00
8.0E+00
NA
8.0E-03
mg/L
Max
Maximum Detected Concentration
Low Molecular Weight PAHs
Hg/L
1.1E-02
1.1E-02
NA
1.1E-05
mg/L
Max
Maximum Detected Concentration
High Molecular Weight PAHs
Hg/L
2.3E-02
2.3E-02
NA
2.3E-05
mg/L
Max
Maximum Detected Concentration
VOCs
156-59-2
cis-l,2-Dichloroethylene
Hg/L
8.0E+00
8.0E+00
NA
8.0E-03
mg/L
Max
Maximum Detected Concentration
108-88-3
Toluene
Hg/L
9.0E+00
9.0E+00
NA
9.0E-03
mg/L
Max
Maximum Detected Concentration
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration.
NA = Not Available; UCL could not be calculated because of low sample number or low detection frequency.
UCL based on USEPA ProUCL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples. It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected
concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95% UCL recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number
of non-detect samples.
Chebyshev (Mean, Sd) UCL = (1-a )100% UCL of the mean based upon the Chebyshev Theorem (using the sample mean and sample standard deviation - non-parametric). Gamma UCL = Computation of UCL of the mean of a amma, G(k,0) distribution
(parametric).
H-UCL = (l-a)100% UCL of the mean based upon H-statistic (H-UCL) (parametric).
KM (BCA) UCL = UCL based upon Kaplan-Meier estimates using the bias corrected accelerated percentile bootstrap method (non-parametric). KM (Chebyshev) UCL = UCL based upon Kaplan-Meier estimates using the Chebyshev inequality (non-parametric).
KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric). Student's-t UCL = Computation method based upon student's t-distribution (parametric).
Page 3 of 3
-------
Table 7-10
Aquatic Exposure Area Surface Water Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents
Units
Average Detected
Maximum Detected
Potential
Exposure Point Concentration
of Concern
Concentration
Concentration
UCL to Use
Value
Units
Statistic3
Rationale'3
METALS
7440-38-2
Arsenic
ug/L
2.1E+00
3.7E+00
2.5E+00
2.5E-03
mg/L
% UCL
95% Student's-t UCL
7440-39-3
Barium
ug/L
5.8E+01
9.2E+01
6.8E+01
6.8E-02
mg/L
% UCL
95% Student's-t UCL
7440-50-8
Copper
ug/L
5.8E+00
7.2E+00
5.5E+00
5.5E-03
mg/L
% UCL
95% KM (t) UCL
7439-89-6
Iron
ug/L
1.1E+03
5.0E+03
3.0E+03
3.0E+00
mg/L
% UCL
95% Chebyshev (Mean, Sd) UCL
7439-92-1
Lead
ug/L
2.7E+00
2.8E+00
2.6E+00
2.6E-03
mg/L
% UCL
95% KM (t) UCL
7439-96-5
Manganese
ug/L
3.2E+02
6.7E+02
4.1E+02
4.1E-01
mg/L
% UCL
95% Student's-t UCL
7440-02-0
Nickel
ug/L
7.1E-01
9.1E-01
7.0E-01
7.0E-04
mg/L
% UCL
95% KM (t) UCL
7440-66-6
Zinc
ug/L
7.0E+00
1.1E+01
8.4E+00
8.4E-03
mg/L
% UCL
95% KM (t) UCL
SVOCs
118-74-1
Hexachlorobenzene
ug/L
3.5E-03
3.7E-03
3.4E-03
3.4E-06
mg/L
% UCL
95% KM (t) UCL
Low Molecular Weight PAHs
ug/L
3.8E-02
7.7E-02
6.4E-02
6.4E-05
mg/L
% UCL
95% KM (Percentile Bootstrap) UCL
High Molecular Weight PAHs
ug/L
7.6E-02
1.5E-01
9.9E-02
9.9E-05
mg/L
% UCL
95% KM (t) UCL
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration.
NA = Not Available; UCL could not be calculated because of low sample number or low detection frequency.
UCL based on USEPA ProUCL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples.
It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95%
UCL recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples.
Chebyshev (Mean, Sd) UCL = (1-a )100% UCL of the mean based upon the Chebyshev Theorem (using the sample mean and sample standard deviation - non-parametric). KM (Percentile Bootstrap) UCL -
(1-a) 100% UCL of the Mean Based Upon Simple Percentile Bootstrap Method (non-parametric).
KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric). Student's-t UCL = Computation method based upon
student's t-distribution (parametric).
Page 1 of 1
-------
Table 7-11
Aquatic Exposure Area Surface Sediment Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Maximum Detected
Potential
Exposure Point Concentration
Concentration
Concentration
UCLto Use
Value
Units
Statistic3
Rationale'3
METALS
7440-38-2
Arsenic
mg/kg
8.7E+00
2.5E+01
1.3E+01
1.3E+01
mg/kg
% UCL
95% Approximate Gamma UCL
7440-39-3
Barium
mg/kg
1.3E+02
3.2E+02
1.8E+02
1.8E+02
mg/kg
% UCL
95% Approximate Gamma UCL
7440-41-7
Beryllium
mg/kg
1.0E+00
1.6E+00
1.2E+00
1.2E+00
mg/kg
% UCL
95% Student's-t UCL
7440-43-9
Cadmium
mg/kg
8.7E-01
3.4E+00
1.7E+00
1.7E+00
mg/kg
% UCL
95% Approximate Gamma UCL
7440-47-3
Chromium
mg/kg
6.3E+01
2.6E+02
9.8E+01
9.8E+01
mg/kg
% UCL
95% Approximate Gamma UCL
7440-48-4
Cobalt
mg/kg
1.2E+01
3.2E+01
1.7E+01
1.7E+01
mg/kg
% UCL
95% Approximate Gamma UCL
7440-50-8
Copper
mg/kg
3.0E+01
5.7E+01
3.8E+01
3.8E+01
mg/kg
% UCL
95% Student's-t UCL
7439-89-6
Iron
mg/kg
2.1E+04
3.1E+04
2.6E+04
2.6E+04
mg/kg
% UCL
95% Student's-t UCL
7439-92-1
Lead
mg/kg
5.5E+01
1.5E+02
8.3E+01
8.3E+01
mg/kg
% UCL
95% Approximate Gamma UCL
7439-96-5
Manganese
mg/kg
1.9E+02
3.2E+02
2.3E+02
2.3E+02
mg/kg
% UCL
95% Student's-t UCL
7439-97-6
Mercury
mg/kg
1.0E-01
2.0E-01
1.4E-01
1.4E-01
mg/kg
% UCL
95% Student's-t UCL
7440-02-0
Nickel
mg/kg
2.3E+01
3.6E+01
2.8E+01
2.8E+01
mg/kg
% UCL
95% Student's-t UCL
7782-49-2
Selenium
mg/kg
6.9E-01
1.3E+00
9.1E-01
9.1E-01
mg/kg
% UCL
95% Student's-t UCL
7440-22-4
Silver
mg/kg
3.6E-01
1.3E+00
7.2E-01
7.2E-01
mg/kg
% UCL
95% Approximate Gamma UCL
7440-28-0
Thallium
mg/kg
4.1E-01
9.4E-01
5.6E-01
5.6E-01
mg/kg
% UCL
95% Student's-t UCL
7440-62-2
Vanadium
mg/kg
4.0E+01
7.7E+01
5.1E+01
5.1E+01
mg/kg
% UCL
95% Student's-t UCL
7440-66-6
Zinc
mg/kg
1.8E+02
6.7E+02
4.5E+02
4.5E+02
mg/kg
% UCL
95% Chebyshev (Mean, Sd) UCL
PCBs
Total PCBs
mg/kg
2.8E-01
5.6E-01
NA
5.6E-01
mg/kg
Max
Maximum Detected Concentration
PESTICIDES
72-54-8
4-4-DDD
mg/kg
3.1E-02
6.2E-02
3.7E-02
3.7E-02
mg/kg
% UCL
95% KM (t) UCL
72-55-9
4-4-DDE
mg/kg
4.7E-02
1.6E-01
7.5E-02
7.2E-02
mg/kg
% UCL
95% KM (BCA) UCL
50-29-3
4-4-DDT
mg/kg
1.7E-01
1.1E+00
6.8E-01
6.8E-01
mg/kg
% UCL
95% KM (Chebyshev)
309-00-2
Aldrin
mg/kg
4.2E-02
7.2E-02
5.4E-02
5.4E-02
mg/kg
% UCL
UCL 95% KM (t) UCL
Constituents of Chlordane
mg/kg
1.4E-02
2.8E-02
2.1E-02
2.1E-02
mg/kg
% UCL
95% KM (t) UCL
60-57-1
Dieldrin
mg/kg
1.1E-01
2.6E-01
1.0E-01
1.0E-01
mg/kg
% UCL
95% KM (t) UCL
1031-07-8
Endosulfan Sulfate
mg/kg
2.0E-02
2.0E-02
NA
2.0E-02
mg/kg
Max
Maximum Detected Concentration
72-20-8
Endrin
mg/kg
4.0E-03
4.0E-03
NA
4.0E-03
mg/kg
Max
Maximum Detected Concentration
7421-93-4
Endrin Aldehyde
mg/kg
2.4E-02
6.9E-02
3.0E-02
3.0E-02
mg/kg
% UCL
95% KM (t) UCL
76-44-8
Heptachlor
mg/kg
9.8E-03
1.3E-02
1.1E-02
1.1E-02
mg/kg
% UCL
95% KM (t) UCL
1024-57-3
Heptachlor Epoxide
mg/kg
2.7E-02
5.8E-02
3.5E-02
3.5E-02
mg/kg
% UCL
95% KM (t) UCL
58-89-9
Lindane
mg/kg
1.4E-02
2.6E-02
3.0E-02
2.6E-02
mg/kg
Max
Maximum Detected Concentration
72-43-5
Methoxychlor
mg/kg
1.8E-02
1.8E-02
NA
1.8E-02
mg/kg
Max
Maximum Detected Concentration
SVOCs
132-64-9
Dibenzofuran
mg/kg
1.7E+00
2.8E+00
2.8E+00
2.8E+00
mg/kg
% UCL
95% KM (BCA) UCL
Low Molecular Weight PAHs
mg/kg
2.2E+01
1.3E+02
8.3E+01
8.3E+01
mg/kg
% UCL
95% KM (Chebyshev)
High Molecular Weight PAHs
mg/kg
2.1E+01
1.5E+02
1.9E+02
1.5E+02
mg/kg
Max
UCL Maximum Detected Concentration
VOCs
95-50-1
1,2-Dichlorobenzene
mg/kg
1.4E-02
1.4E-02
NA
1.4E-02
mg/kg
Max
Maximum Detected Concentration
Page 1 of 2
-------
Table 7-11
Aquatic Exposure Area Surface Sediment Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential
UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale!3
541-73-1
1,3-Oichlorobenzene
mg/kg
3.0E-03
3.0E-03
NA
5.9E-01
mg/kg
Max
Maximum Detected Concentration
106-46-7
1,4-Dichlorobenzene
mg/kg
1.1E-02
1.1E-02
NA
5.9E-01
mg/kg
Max
Maximum Detected Concentration
100-52-7
Benzaldehyde
mg/kg
5.9E-01
5.9E-01
NA
5.9E-01
mg/kg
Max
Maximum Detected Concentration
75-15-0
Carbon Disulfide
mg/kg
4.0E-03
4.0E-03
NA
4.0E-03
mg/kg
Max
Maximum Detected Concentration
108-90-7
Chlorobenzene
mg/kg
5.4E+00
5.4E+00
NA
5.4E+00
mg/kg
Max
Maximum Detected Concentration
110-82-7
Cyclohexane
mg/kg
2.0E-03
2.0E-03
NA
2.0E-03
mg/kg
Max
Maximum Detected Concentration
75-65-0
tert-ButylAIcohoI
mg/kg
1.4E-01
1.4E-01
NA
1.4E-01
mg/kg
Max
Maximum Detected Concentration
Notes;
a; Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration.
NA = Not Available; UCl could not be calculated because of low sample number or low detection frequency.
UCL based on USEPA ProUCL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples.
It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples,
causing the 95% UCL recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples.
Chebyshev (Mean, Sd) UCL = (1-a )100% UCL of the mean based upon the Chebyshev Theorem (using the sample mean and sample standard deviation - non-parametric). Gamma UCL
= Computation of UCL of the mean of a Gamma, G(k,0) distribution (parametric).
KM (BCA) UCL = UCL based upon Kaplan-Meier estimates using the bias corrected accelerated percentile bootstrap method (non-parametric). KM (Chebyshev) UCL =
UCL based upon Kaplan-Meier estimates using the Chebyshev inequality (non-parametric).
KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric). Student's-t UCL = Computation
method based upon student's t-distribution (parametric).
Pago 2 of 2
-------
Table 7-12
Shallow Groundwater Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Maximum Detected
Potential UCL
Exposure Point Concentration
Concentration
Concentration
to Use
Value
Units
Statistic3
Rationale'5
METALS
7440-38-2
Arsenic
ug/L
1.5E+02
2.9E+02
2.3E+02
2.3E-01
mg/L
% UCL
95% KM (t) UCL
7440-39-3
Barium
ug/L
1.4E+02
2.4E+02
2.0E+02
2.0E-01
mg/L
% UCL
95% Approximate Gamma UCL
7440-50-8
Copper
ug/L
5.7E-01
6.3E-01
6.0E-01
6.0E-04
mg/L
% UCL
95% KM (t) UCL
7439-89-6
Iron
ug/L
5.5E+04
9.7E+04
9.1E+04
9.1E+01
mg/L
% UCL
95% Student's-t UCL
7439-92-1
Lead
ug/L
1.5E-01
2.1E-01
1.8E-01
1.8E-04
mg/L
% UCL
95% Student's-t UCL
7439-96-5
Manganese
ug/L
6.6E+02
1.4E+03
1.7E+03
1.4E+00
mg/L
% UCL
95% Chebyshev (Mean, Sd) UCL
7439-97-6
Mercury
ug/L
3.4E-02
3.4E-02
NA
3.4E-05
mg/L
Max
Maximum Detected Concentration
7440-02-0
Nickel
ug/L
1.4E+00
1.7E+00
1.7E+00
1.7E-03
mg/L
% UCL
95% KM (t) UCL
7440-66-6
Zinc
ug/L
8.2E+00
1.5E+01
1.1E+01
1.1E-02
mg/L
% UCL
95% Student's-t UCL
PESTICIDES
72-54-8
4-4-DDD
ug/L
5.5E-03
5.5E-03
NA
5.5E-06
mg/L
Max
Maximum Detected Concentration
Constituents of Chlordane
ug/L
3.1E-03
3.1E-03
3.7E-03
3.1E-06
mg/L
% UCL
95% KM (t) UCL
1024-57-3
Heptachlor Epoxide
ug/L
2.5E-03
2.5E-03
NA
2.5E-06
mg/L
Max
Maximum Detected Concentration
SVOCs
Low Molecular Weight PAHs
ug/L
2.0E-01
3.5E-01
2.8E-01
2.8E-04
mg/L
% UCL
95% KM (Percentile Bootstrap) UCL
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProLICL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration.
UCL based on USEPA ProLICL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples.
It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95% UCL
recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples.
NA = Not Available; UCL could not be calculated because of low sample number or low detection frequency.
KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric).
KM (Percentile Bootstrap) UCL - (1-a) 100% UCL of the Mean Based Upon Simple Percentile Bootstrap Method (non-parametric). Student's-t UCL= Computation method based upon student's t-
distribution (parametric).
Chebyshev (Mean, Sd) UCL= (1-a )100% UCL of the mean based upon the Chebyshev Theorem (using the sample mean and sample standard deviation - non-parametric).
Gamma UCL = Computation of UCL of the mean of a Gamma, G(k,0) distribution (parametric).
Page 1 of 1
-------
Table 7-13
Terrestrial Invertebrate Tissue Exposure Point Concentrations
Triangle-Pacific Corporation Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale15
METALS
7440-36-0
Antimony
mg/kg
5.2E-01
5.2E-01
NA
5.2E-01
mg/kg
Max
Maximum Detected Value
7440-38-2
Arsenic
mg/kg
1.3E+00
1.6E+00
1.3E+00
1.3E+00
mg/kg
% UCL
95% KM (t) UCL
7440-39-3
Barium
mg/kg
3.3E+01
1.1E+02
6.3E+01
6.3E+01
mg/kg
% UCL
95% Student's-t UCL
7440-43-9
Cadmium
mg/kg
3.7E+00
6.8E+00
5.3E+00
5.3E+00
mg/kg
% UCL
95% KM (t) UCL
7440-47-3
Chromium
mg/kg
1.8E+00
4.1E+00
2.5E+00
2.5E+00
mg/kg
% UCL
95% KM (t) UCL
7440-50-8
Copper
mg/kg
1.2E+01
5.8E+01
5.5E+01
5.5E+01
mg/kg
% UCL
95% Adjusted Gamma UCL
7439-89-6
Iron
mg/kg
7.2E+02
2.8E+03
3.1E+03
2.8E+03
mg/kg
Max
95% Adjusted Gamma UCL
7439-92-1
Lead
mg/kg
2.0E+01
8.1E+01
4.0E+01
4.0E+01
mg/kg
% UCL
95% KM (t) UCL
7439-96-5
Manganese
mg/kg
2.1E+01
4.2E+01
3.1E+01
3.1E+01
mg/kg
% UCL
95% Student's-t UCL
7439-97-6
Mercury
mg/kg
1.1E-01
2.2E-01
1.5E-01
1.5E-01
mg/kg
% UCL
95% KM (t) UCL
7440-02-0
Nickel
mg/kg
1.0E+00
2.4E+00
1.4E+00
1.4E+00
mg/kg
% UCL
95% KM (t) UCL
7782-49-2
Selenium
mg/kg
2.5E+00
6.3E+00
4.0E+00
4.0E+00
mg/kg
% UCL
95% KM (t) UCL
7440-22-4
Silver
mg/kg
4.2E-01
4.2E-01
NA
4.2E-01
mg/kg
Max
Maximum Detected Value
7440-62-2
Vanadium
mg/kg
7.9E-01
1.6E+00
1.4E+00
1.4E+00
mg/kg
% UCL
99% KM (Chebyshev) UCL
7440-66-6
Zinc
mg/kg
1.4E+02
3.2E+02
2.3E+02
2.3E+02
mg/kg
% UCL
95% Student's-t UCL
PCBs
Total PCBs
mg/kg
8.9E-01
2.3E+00
1.1E+00
1.1E+00
mg/kg
% UCL
95% KM (t) UCL
PESTICIDES
72-54-8
4-4-DDD
mg/kg
1.7E-02
3.2E-02
4.2E-02
3.2E-02
mg/kg
Max
97.5% KM (Chebyshev) UCL
72-55-9
4-4-DDE
mg/kg
5.1E-02
1.0E-01
2.0E-01
1.0E-01
mg/kg
Max
95% KM (Chebyshev) UCL
50-29-3
4-4-DDT
mg/kg
6.1E-02
3.1E-01
4.9E-01
3.1E-01
mg/kg
Max
99% KM (Chebyshev) UCL
309-00-2
Aldrin
mg/kg
1.0E-03
1.0E-03
NA
1.0E-03
mg/kg
Max
Maximum Detected Value
Constituents of Chlordane
mg/kg
1.4E-02
3.8E-02
2.0E-02
2.0E-02
mg/kg
% UCL
95% KM (t) UCL
60-57-1
Dieldrin
mg/kg
3.9E-03
3.9E-03
NA
3.9E-03
mg/kg
Max
Maximum Detected Value
33213-65-9
Endosulfan II
mg/kg
3.0E-03
4.3E-03
2.9E-03
2.9E-03
mg/kg
% UCL
95% KM (t) UCL
72-20-8
Endrin
mg/kg
1.1E-03
1.5E-03
1.3E-03
1.3E-03
mg/kg
% UCL
95% KM (t) UCL
7421-93-4
Endrin Aldehyde
mg/kg
1.2E-02
2.3E-02
3.0E-02
2.3E-02
mg/kg
Max
97.5% KM (Chebyshev) UCL
76-44-8
Heptachlor
mg/kg
2.0E-03
2.9E-03
2.5E-03
2.5E-03
mg/kg
% UCL
95% KM (t) UCL
1024-57-3
Heptachlor Epoxide
mg/kg
1.6E-03
1.9E-03
1.7E-03
1.7E-03
mg/kg
% UCL
95% KM (t) UCL
58-89-9
Lindane
mg/kg
2.8E-03
3.2E-03
2.5E-03
2.5E-03
mg/kg
% UCL
95% KM (t) UCL
72-43-5
Methoxychlor
mg/kg
5.5E-03
5.5E-03
NA
5.5E-03
mg/kg
Max
Maximum Detected Value
SVOCs
Low Molecular Weight PAHs
mg/kg
3.8E-01
6.3E-01
4.6E-01
4.6E-01
mg/kg
% UCL
95% KM (t) UCL
High Molecular Weight PAHs
mg/kg
4.1E-01
1.2E+00
8.85E-01
8.9E-01
mg/kg
% UCL
95% KM (t) UCL
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration.
NA = Not Available;
UCL could not be calculated because of low sample number or low detection frequency.
UCL based on USEPA ProUCL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples. It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a
low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95% UCL recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples.
Gamma UCL = Computation of UCL of the mean of a Gamma, G(k,0) distribution (parametric).
KM (Chebyshev) UCL = UCL based upon Kaplan-Meier estimates using the Chebyshev inequality (non-parametric). KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric). Student's-t UCL = Computation method based upon student's
t-distribution (parametric).
Page 1 of 1
-------
Table 7-14
Aquatic Invertebrate Tissue Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of
Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential UCL to Use
Exposure Point Concentration
Value
Units
Statistic3
Rationale'3
METALS
7440-38-2
Arsenic
mg/kg
1.58E-01
1.99E-01
2.03E-01
1.99E-01
mg/kg
Max
Maximum Detected Value
7440-39-3
Barium
mg/kg
5.62E+01
8.63E+01
8.32E+01
8.32E+01
mg/kg
% UCL
95% Student's-t UCL
7440-47-3
Chromium
mg/kg
3.36E-01
5.58E-01
5.28E-01
5.28E-01
mg/kg
% UCL
95% KM (t) UCL
7440-50-8
Copper
mg/kg
1.03E+01
1.20E+01
1.24E+01
1.20E+01
mg/kg
Max
Maximum Detected Value
7439-89-6
Iron
mg/kg
6.39E+01
9.67E+01
9.83E+01
9.67E+01
mg/kg
Max
Maximum Detected Value
7439-92-1
Lead
mg/kg
1.19E+00
1.71E+00
2.00E+00
1.71E+00
mg/kg
Max
Maximum Detected Value
7439-96-5
Manganese
mg/kg
1.32E+02
1.74E+02
1.90E+02
1.74E+02
mg/kg
Max
Maximum Detected Value
7439-97-6
Mercury
mg/kg
2.13E-02
2.69E-02
2.80E-01
2.69E-02
mg/kg
Max
Maximum Detected Value
7440-02-0
Nickel
mg/kg
1.74E-01
2.25E-01
2.23E-01
2.23E-01
mg/kg
% UCL
95% KM (t) UCL
7782-49-2
Selenium
mg/kg
1.81E-01
2.24E-01
2.36E-01
2.24E-01
mg/kg
Max
Maximum Detected Value
7440-22-4
Silver
mg/kg
1.11E-01
1.32E-01
1.42E-01
1.32E-01
mg/kg
Max
Maximum Detected Value
7440-62-2
Vanadium
mg/kg
9.02E-02
1.43E-01
1.32E-01
1.32E-01
mg/kg
% UCL
95% Student's-t UCL
7440-66-6
Zinc
mg/kg
2.28E+01
2.88E+01
2.81E+01
2.81E+01
mg/kg
% UCL
95% Student's-t UCL
PESTICIDES
72-54-8
4-4-DDD
mg/kg
4.47E-04
5.20E-04
5.00E-04
5.00E-04
mg/kg
% UCL
95% KM (t) UCL
72-55-9
4-4-DDE
mg/kg
1.11E-03
1.60E-03
1.70E-03
1.60E-03
mg/kg
Max
Maximum Detected Value
60-57-1
Dieldrin
mg/kg
3.90E-04
3.90E-04
NA
3.90E-04
mg/kg
Max
Maximum Detected Value
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b:ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration. UCL based
on USEPA ProUCL (V. 5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples.
It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95%
UCL recommended by ProUCL V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples. The UCL can also be higher than the maximum detected concentration, due to a low sample
size. In these instances, the maximum detected value is used as the EPC.
NA = Not available; UCL could not be calculated because of low sample number or low detection frequency.
KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-distribution critical value (non-parametric). Student's-t UCL = Computation method based upon
student's t-distribution (parametric).
Page 1 of 1
-------
Table 7-15
Fish Tissue Exposure Point Concentrations
Triangle-Pacific Site
Elizabeth City, North Carolina
CAS Number
Constituents of Concern
Units
Average Detected
Concentration
Maximum Detected
Concentration
Potential UCL to Use
Exposure
Point Concentration
Value
Units
Statistic3
Rationale'5
METALS
7440-38-2
Arsenic
mg/kg
2.2E-01
3.8E-01
2.7E-01
2.7E-01
mg/kg
%UCL
95% KM (t) UCL
7440-39-3
Barium
mg/kg
1.7E+00
2.8E+00
2.2E+00
2.2E+00
mg/kg
%UCL
95% Student's-t UCL
7440-47-3
Chromium
mg/kg
2.0E-01
2.6E-01
1.8E-01
1.8E-01
mg/kg
%UCL
95% KM (t) UCL
7440-48-4
Cobalt
mg/kg
4.5E-02
4.5E-02
NA
4.5E-02
mg/kg
Max
Maximum Detected Value
7440-50-8
Copper
mg/kg
3.9E+00
1.2E+01
6.8E+00
6.8E+00
mg/kg
%UCL
95% Student's-t UCL
7439-89-6
Iron
mg/kg
2.7E+01
6.3E+01
4.9E+01
4.9E+01
mg/kg
%UCL
95% Approximate Gamma UCL
7439-92-1
Lead
mg/kg
1.5E-01
7.0E-01
5.0E-01
5.0E-01
mg/kg
%UCL
95% Chebyshev (Mean, Sd) UCL
7439-96-5
Manganese
mg/kg
3.8E+00
8.1E+00
5.3E+00
5.3E+00
mg/kg
%UCL
95% Student's-t UCL
7439-97-6
Mercury
mg/kg
7.5E-02
1.6E-01
1.1E-01
1.1E-01
mg/kg
%UCL
95% Student's-t UCL
7440-02-0
Nickel
mg/kg
7.3E-02
7.9E-02
4.9E-02
4.9E-02
mg/kg
%UCL
95% KM (t) UCL
7782-49-2
Selenium
mg/kg
4.0E-01
5.4E-01
4.9E-01
4.9E-01
mg/kg
%UCL
95% Student's-t UCL
7440-22-4
Silver
mg/kg
2.9E-02
4.7E-02
2.8E-02
2.8E-02
mg/kg
%UCL
95% KM (t) UCL
7440-62-2
Vanadium
mg/kg
5.9E-02
1.0E-01
8.2E-02
8.2E-02
mg/kg
%UCL
95% Student's-t UCL
7440-66-6
Zinc
mg/kg
2.1E+01
2.7E+01
2.3E+01
2.3E+01
mg/kg
%UCL
95% Student's-t UCL
PCBs
Total PCBs
mg/kg
4.0E-02
9.3E-02
6.3E-02
6.3E-02
mg/kg
%UCL
95% Student's-t UCL
PESTICIDES
72-54-8
4-4-DDD
mg/kg
3.0E-03
5.9E-03
3.8E-03
3.8E-03
mg/kg
% UCL
95% KM (t) UCL
72-55-9
4-4-DDE
mg/kg
1.8E-02
3.5E-02
2.6E-02
2.6E-02
mg/kg
% UCL
95% Student's-t UCL
50-29-3
4-4-DDT
mg/kg
1.9E-03
4.4E-03
2.8E-03
2.8E-03
mg/kg
% UCL
95% KM (t) UCL
Constituents of Chlordane
mg/kg
9.0E-04
2.1E-03
1.2E-03
1.2E-03
mg/kg
% UCL
95% KM (t) UCL
60-57-1
Dieldrin
mg/kg
1.3E-03
2.3E-03
1.7E-03
1.7E-03
mg/kg
% UCL
95% Student's-t UCL
1031-07-8
Endosulfan Sulfate
mg/kg
8.5E-04
2.2E-03
1.3E-03
1.3E-03
mg/kg
% UCL
95% KM (t) UCL
72-20-8
Endrin
mg/kg
9.0E-04
2.3E-03
1.4E-03
1.4E-03
mg/kg
% UCL
95% Student's-t UCL
1024-57-3
Heptachlor Epoxide
mg/kg
7.3E-04
8.1E-04
7.6E-04
7.6E-04
mg/kg
% UCL
95% KM (t) UCL
Notes:
a: Max - maximum detected concentration; %UCL - % upper confidence limit.
b: ProUCL does not provide 95% UCLs when there are insufficient data, as defined by fewer than 3 samples or fewer than 2 unique detected samples. In these cases, the EPC is obtained by using the maximum detected concentration. UCL based on USEPA ProUCL (V.
5.0; USEPA 2013) recommendation, using Regression on Order Statistics (ROS) for evaluating data with non-detect (ND) samples.
It is possible that in certain instances, the calculated 95% UCL is smaller than the mean detected concentration. This reflects a low detection frequency and non-detect samples largely outnumbering detected samples, causing the 95% UCL recommended by ProUCL
V5.0 to be smaller than the mean detected concentration, since it reflects the large number of non-detect samples.
NA = Not Available; UCL could not be calculated because of low sample number or low detection frequency.
Chebyshev (Mean, Sd) UCL = (1-a )100% UCL of the mean based upon the Chebyshev Theorem (using the sample mean and sample standard deviation - non-parametric). Gamma UCL= Computation of UCL of the mean of a
Gamma, G(k,0) distribution (parametric).
KM (Percentile Bootstrap) UCL = UCL based upon Kaplan-Meier estimates using the percentile bootstrap method. KM (t) UCL = UCL based upon Kaplan-Meier estimates using student's t-
distribution critical value (non-parametric). Student's-t UCL = Computation method based upon student's t-distribution (parametric).
Page 1 of 1
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Table 7-16
Ecological Exposure Pathways of Concern
Triangle-Pacific Site
Elizabeth City, North Carolina
Exposure
Area
Exposure
Medium
Sensitive
Environment
Flag
(Y/N)
Receptor
Endangered or
Threatened
Species Flag
Exposure Routes
Assessment Endpoints
Measurement Endpoints
Terrestrial
Exposure
Area
Surface Soil
N
Terrestrial plants,
invertibrates,
invertivorous &
predatory birds,
invertivorous &
omnivorous
mammals
Y
Direct contact,
incidental
ingestion, and
ingestion of
affected food
items.
Reproductive success, growth, and/or
survival) of invertivorous and predatory
bird, and invertivorous and omnivorous
mammal populations likely to forage on
prey available from terrestrial portions of
the Site; health of plant and soil
invertebrate communities.
1. Comparison of the modeled dietary doses, based on Site surface soil and surface water COC
concentrations, to TRVs for the American robin.
2, Comparison of soil EPCs of COCs to Eco-SSL values for birds, plants, mammals, and invertebrates.
3. Comparison of modeled dietary doses, based on Site surface soil and surface water EPCs of COCs,
to TRVs for the southern short-tailed shrew.
4, Comparison of the dietary doses, based on Site surface soil and surface water EPCs and modeled
plant, soil invertebrate, and small mammal tissue COC concentrations, to TRVs for the raccoon.
Surface
Water
N
Fish, piscivorous bird
and mammal
populations
N
Direct contact,
incidental
ingestion, and
aquatic food chain.
Toxic effects to aquatic organisms and
wildlife via direct contact with Site
surface waters; reproductive success,
growth, and/or survival of the Pailin
Creek fish community and piscivorous
bird and mammal populations
1. Comparison of dietary doses, based on surface water, and modeled small mammal tissue EPCs, to
TRVs for the red-tailed hawk.
Aquatic
Exposure
Area
Sediment
N
Benthic organisms
N
Direct contact,
incidental
ingestion, and
aquatic food chain.
Toxic effects to the Pailin Creek aquatic
invertebrate community via direct
contact with Site sediments
1. Comparison of sediment EPCs of COCs in Pailin Creek to state and federal sediment criteria and
guidance values (Region 4 Waste Management Division Screening Values for Hazardous Waste Sites
[chronic], [USEPA 2001b, ECO Update: EcoTOX Thresholds [USEPA 1996]).
2. Comparison of EPCs of COCs in Pailin Creek crab tissue to criteria for the protection of aquatic
invertebrates.
3. Comparison of EPCs of COCs in Pailin Creek crab tissue to criteria for the protection of piscivorous
mammals.
Surface
Water
N
Fish, piscivorous bird
and mammal
populations
N
Direct contact,
incidental
ingestion, and
aquatic food chain.
Toxic effects to aquatic organisms and
wildlife via direct contact with Site
surface waters; viability of the fish
community.
1. Comparison of surface water EPCs of Pailin Creek COCs to state and federal surface water criteria
and guidance from:
» Region 4 Waste Management Division Screening Values for Hazardous Waste Sites (chronic) (USEPA
2001b)
» Region 3 BTAG Marine Screening Benchmarks (USEPA 2013a)
» NCDEQ Saltwater Aquatic Life Standards (https://deq.nc.gov/nc-stdstable-09222017) per the North
Carolina 15A NCAC 02B Water Quality Standards for Surface Waters
» National Recommended Water Quality Criteria (USEPA 2013b)
» USEPA EcoTOX Screening Criteria AWCQ/Tier II Values (USEPA 1996).
2. Comparison of dietary doses based on EPCs in Pailin Creek sediment, surface water, and measured
prey (i.e., crab, finfish) COC tissue concentrations to TRVs for the green heron and great blue heron.
Shallow
Groundwater
N
Piscivorous bird and
mammal populations
N
Direct contact,
incidental
ingestion, and
ingestion of
affected prey
species.
Toxic effects to aquatic organisms and
wildlife via direct contact with Site
groundwater that seeps to surface water
bodies
3. Comparison of EPCs of Site shallow groundwater COCs to state and federal surface water criteria
and guidance from:
» Region 4 Waste Management Division Screening Values for Hazardous Waste Sites (chronic) (USEPA
2001b)
» Region 3 BTAG Marine Screening Benchmarks (USEPA 2013a)
» NCDEQ Saltwater Aquatic Life Standards (https://deq.nc.gov/nc-stdstable-09222017) per the North
Carolina 15A NCAC 02B Water Quality Standards for Surface Waters
» National Recommended Water Quality Criteria (USEPA 2013b)
» USEPA EcoTOX Screening Criteria AWCQ/Tier II Values (USEPA 1996).
Page 1 of 1
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FEASIBILITY STUDY
Table 11-1
Summary of Comparative Analysis of Soil Remedial Alternatives
Triangle Pacific Site
Elizabeth City, North Carolina
Alternative 1 - No Further Action
- Discontinuation of Monitoring, Operations, and Maintenance
Alternative 2 - Limited Excavation/Disposal and Unrestricted Use
- Excavation and Off-Site Disposal
- Back-filling of excavated areas with certified clean fill
Overall Protection of Human Health and the Environment
Overall Protection of Human Health
Under the current and expected future industrial-use conditions at the Site, soil constituents do not pose
risks to human health.
Under the current and expected future industrial-use conditions at the Site, soil constituents do not pose
risks to human health.
Overall protection of the environment
Because the areas with highest detections of COCs are not located beneath or near impermeable surfaces,
this alternative would not provide a means to mitigate potential risks associated with exposed soil. Local
fauna would still have access to soil contaminated with COCs under Alternative 1.
Overall protection of the environment is provided through the removal of affected soil from the Site,
thus mitigating aggregate ecological risk via direct contact with or ingestion of soil COCs.
Attainment of RAOs
Alternative 1 does not address soil RAOs because surface soil containing COCs remains accessible to local
fauna.
Alternative 2 addresses soil RAOs through removal of impacted soil.
Compliance with ARARs and TBCs
Compliance with chemical-specific ARARs and TBCs
This alternative would not comply with chemical-specific ARARs.
Alternative 2 would attain chemical-specific ARARs by removing soil characterized as PCB Remediation
Waste (> 50 mg/kg total PCBs) under TSCA.
Compliance with location-specific ARARs and TBCs
No location-specific ARARs are triggered by this alternative.
Excavation and backfilling activities would be conducted in a manner consistent with floodplain and
protected species regulations. Excavation and backfilling activities would be performed so as to protect
nearby water bodies from incidental pollution.
Compliance with action-specific ARARs and TBCs
No actions are included in this alternative.
Excavation and backfilling activities would be conducted in a manner consistent with air quality standards
and in accordance to OSHA safety requirements. Solid and hazardous wastes would be managed in
accordance with applicable state and federal handling and disposal regulations, including TSCA
requirements for PCBs. Transportation activities would be completed in accordance with applicable state
and federal requirements, by licensed and permitted haulers.
Long-Term Effectiveness and Permanence
Magnitude of residual risk
No additional actions are implemented under Alternative 1, therefore, impacts to ecological receptors
remain on-site following implementation of this remedial alternative. Because of the nature of compounds
in the soil, natural degradation is unlikely to occur, and the associated risks are expected to persist.
Following implementation of Alternative 2, no unacceptable ecological risks would remain.
Adequacy and reliability of controls
No controls are included in this alternative related to direct contact with soil.
Excavation and off-site disposal of soil included in Alternative 2 is a reliable means of managing potential
exposures to soil affected by COCs, thereby mitigating aggregate ecological risk. Alternative 2 would
attain chemical-specific ARARs by removing soil characterized as PCB Remediation Waste (> 50 mg/kg
total PCBs) under TSCA.
Sustainability and environmental impacts
No energy consumption, greenhouse gas or pollutant emissions, water or resource use, impacts to water,
ecology, or community are anticipated for this alternative.
No long-term pollutant emissions, impacts to water, ecology, or community are anticipated for this
alternative. Some greenhouse gas emissions from construction equipment are anticipated during
excavation activities.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Treatment or recycling processes employed and
materials treated
Alternative 1 does not include active treatment processes.
Alternative 2 does not include active treatment processes. Excavated soils are not anticipated to be
suitable for beneficial reuse elsewhere on site or off site.
Amount of hazardous substances, pollutants, or COCs
that would be treated or recycled
None - because of the nature of the compounds, COCs are unlikely to naturally degrade.
Approximately 34 tons of non-hazardous and 11 tons of hazardous (PCBs >50 mg/kg) soil would be
excavated and disposed off-site at an appropriately permitted landfill.
Degree of expected reduction in toxicity, mobility, or
volume
This alternative would rely solely on natural attenuation to reduce toxicity, mobility, and volume, which,
due to the nature of the COC compounds, is unlikely to occur.
Excavation and disposal of affected soils would completely remove impacted soil, thereby reducing
toxicity, mobility, and volume. Of the proposed alternatives, Alternative 2 would result in the reduction
in toxicity, mobility, and volume through soil removal.
Degree to which treatment is irreversible
Not Applicable
Excavation and off-site disposal is irreversible.
Type and quantity of residuals remaining after
treatment
Not Applicable
No treatment residuals would be created as a result of implementation of Alternative 2.
Degree to which treatment would reduce the inherent
hazards posed by the facility
Not Applicable
Not Applicable
OBG | THERE'S A WAY
0
TABLE 11-1 DETAILED ANALYSIS OF REMEDIAL ALTS -
SOIL (FS APR-18) | PAGE 1 OF 2
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FEASIBILITY STUDY
Table 11-1
Summary of Comparative Analysis of Soil Remedial Alternatives
Triangle Pacific Site
Elizabeth City, North Carolina
Alternative 1 - No Further Action
- Discontinuation of Monitoring, Operations, and Maintenance
Alternative 2 - Limited Excavation/Disposal and Unrestricted Use
- Excavation and Off-Site Disposal
- Back-filling of excavated areas with certified clean fill
Ability of alternative to reduce the toxicity, mobility,
and volume of COCs
Alternative 1 relies solely on natural attenuation to reduce toxicity, mobility, and volume, which due to the
nature of the COC compounds, is unlikely to occur.
Alternative 2 achieves a faster reduction in toxicity, mobility, and volume of COCs than Alternative 1
through the removal of impacted soils from the Site.
Short-Term Effectiveness and Impacts
Potential human exposures during implementation of
the alternative
Alternative 1 does not include active treatment processes.
Physical hazards relating to the movement of heavy equipment and vehicles associated with remedial
construction activities would be anticipated. Chemical hazards related to Site COCs in dust and surface
runoff would be anticipated and controlled appropriately during excavation.
Sustainability and environmental impacts
There are no additional short-term environmental and sustainability impacts expected for implementing
this alternative. No energy consumption, greenhouse gas or pollutant emissions, no water or resource use,
no impacts to water, ecology, workers, or community are anticipated.
Alternative 2 would have higher fuel use/greenhouse gas emissions than Alternative 1 because of the
operation of construction equipment and off-Site transportation of waste. Alternative 2 would have a
greater short-term environmental and community impact than Alternative 1, because of increased
construction traffic during excavation activities. Proper construction controls would be implemented to
minimize environmental and community impact.
Potential nuisance conditions
There are no nuisance conditions associated with implementing this alternative.
Anticipated nuisance conditions associated with Alternative 2 include dust and noise generation, runoff,
and additional traffic due to construction equipment. Proper construction controls would be
implemented to provide community protection.
Protection of workers during remedial actions
No active components are associated with implementing this alternative.
Applicable hazards would be identified and proper health and safety measures would be established in a
project-specific Health and Safety Plan (HASP) to be protective of workers and the community.
Construction procedures including dust suppression, erosion control, and construction hours could be
implemented to address nuisance conditions.
Time until RAOs are achieved
With this alternative, RAOs would not be met for an extensive period of time.
Soil RAOs would be met immediately upon completion of Alternative 2. Alternative 2 is anticipated to be
completed within one construction season.
Implementability
Technical Feasibility - ability to construct and operate
the remedial technology
There are no technologies to be constructed in this alternative.
Remedial elements are readily constructible and operable, and have been previously implemented
successfully at the Site.
Ability to monitor effectiveness of remedy
Not Applicable
The remedy in Alternative 2 could be easily monitored through periodic Site inspections directed by the
Site Management Plan.
Reliability of technology
Not Applicable
Excavation of soils and site restoration is a reliable means of addressing contaminated soils.
Ease of undertaking additional remedial actions, if
necessary
Additional remedial actions, if necessary, would be readily implementable.
Additional remedial actions, if necessary, would be readily implementable.
Availability of off-site treatment storage and disposal
services and capacities
None required.
Off-Site Treatment, Storage, and Disposal Facilities (TSDF) are readily available to manage soil that would
be shipped from Site during implementation of this Alternative.
Availability of necessary equipment, specialists, and
materials
None required.
Equipment, specialists, and materials for this remedy are widely available.
Potential difficulties in obtaining operation approvals
No coordination is necessary with this alternative.
Potential for additional on-site traffic due to construction equipment could impact the day-to-day
activities of one of the current site owners, TCOM LP. Based on past experience with similar removals at
this Site, no difficulties are anticipated in obtaining operation approvals.
Cost
Total present worth capital cost
$0
$151,050
Total present worth O&M cost
$0
$0
Approximate total present worth project cost
$0
$151,050
OBG | THERE'S A WAY
TABLE 11-1 DETAILED ANALYSIS OF REMEDIAL ALTS - SOIL (FS APR-18) | PAGE 2 OF 2
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Table 11-2
Summary of Comparative Analysis of Groundwater Remedial Alternatives
Triangle Pacific Site
Elizabeth City, North Carolina
Alternative 1 - No Further Action
- Discontinuation of Monitoring, Operations, and Maintenance
Alternative 2 -Institutional Controls
- Deed Restrictions to Control Future Use of Property and Groundwater.
- Site Management Plan to Control Development Near MW-03
Alternative 3 - Enhanced Bioremediation with MNA and Institutional Controls
- Deed Restrictions to Prevent Future Residential Use of Property
- Site Management Plan to Prevent Future Development Near MW-03
- Enhanced Monitored Bioremediation with long-term monitoring
Overall Protection of Human Health and the Environment
Overall Protection of Human Health
Under the current and expected future industrial-use conditions
at the Site, there are no risks associated with ingestion of or
direct contact with Site groundwater; however, there would be
a potential risk for human exposure from vapor intrusion were a
building to be constructed near monitoring well MW-03. The no-
action alternative would not provide protection against a
potential vapor intrusion risk if construction or development
were to occur on Site near well MW-03. The groundwater
migration evaluation (Section 2.6.2) performed indicates that
groundwater impacted with TCE would not impact offsite
groundwater or surface water POEs.
Under the current and expected future industrial-use conditions at the Site,
there are no risks associated with ingestion of or direct contact with Site
groundwater; however, there would be a potential risk for human exposure
from vapor intrusion were a building to be constructed near monitoring well
MW-03. Institutional controls mitigating future development near MW-03
would prevent risks associated with vapor intrusion. The groundwater
migration evaluation (Section 2.6.2) indicates that groundwater impacted
with TCE would not impact offsite groundwater or surface water POEs. Deed
restrictions would control future use of the property and the groundwater to
prevent potential human exposures.
Under the current and expected future industrial-use conditions at the Site,
there are no risks associated with ingestion of or direct contact with Site
groundwater; however, there would be a potential risk for human exposure from
vapor intrusion were a building to be constructed near monitoring well MW-03.
Overall protection from potential vapor intrusion risks resulting from building
construction near well MW-03 would be provided through institutional controls
until enhanced bioremediation can reduce concentrations sufficiently to mitigate
the vapor intrusion risk. The groundwater migration evaluation (Section 2.6.2)
indicates that groundwater impacted with TCE would not impact offsite
groundwater or surface water POEs. Deed restrictions would control future use
of the property and the groundwater to prevent potential human exposures.
Groundwater monitoring would be performed to demonstrate the efficacy of
treatment and provide further evaluation of natural attenuation and migration.
Overall protection of the environment
There are no ecological risks associated with the groundwater at
the Site. The groundwater migration evaluation (Section 2.6.2)
performed indicates that groundwater impacted with TCE would
not impact offsite groundwater or surface water POEs.
There are no ecological risks associated with the groundwater at the Site. The
groundwater migration evaluation (Section 2.6.2) performed indicates that
groundwater impacted with TCE would not impact offsite groundwater or
surface water POEs.
There are no ecological risks associated with the groundwater at the Site. The
groundwater migration evaluation (Section 2.6.2) performed indicates that
groundwater impacted with TCE would not impact offsite groundwater or
surface water POEs.
Attainment of RAOs
While natural attenuation could reduce TCE concentration over
time, Alternative 1 would not address groundwater RAOs, as it
would not provide protection against future construction or
development near well MW-03, and associated human exposure
risks through potential vapor intrusion.
Groundwater RAOs associated with vapor intrusion would be met
immediately upon implementation of institutional controls. Natural
attenuation could reduce TCE concentration overtime.
Alternative 3 could potentially address the groundwater RAOs by reducing TCE
concentrations in groundwater near MW-03 through enhanced bioremediation.
Compliance with ARARs and TBCs
Compliance with chemical-specific ARARs and
TBCs
This alternative would not comply with chemical-specific ARARs
for vapor intrusion. The groundwater migration evaluation
(Section 2.6.2) performed indicates that groundwater impacted
with TCE would not reach offsite groundwater or surface water
POEs at concentrations that exceed chemical-specific ARARs.
Natural attenuation could reduce TCE concentration over time.
Alternative 2 would address chemical-specific vapor intrusion ARARs using
institutional controls to control construction near well MW-03. The
groundwater migration evaluation (Section 2.6.2) performed indicates that
groundwater impacted with TCE would not reach offsite groundwater or
surface water POEs at concentrations that exceed chemical-specific ARARs.
Natural attenuation could reduce TCE concentration over time.
Alternative 3 could potentially reduce TCE in groundwater to concentrations
below chemical-specific vapor intrusion ARARs. The groundwater migration
evaluation (Section 2.6.2) performed indicates that groundwater impacted with
TCE would not reach offsite groundwater or surface water POEs at
concentrations that exceed chemical-specific ARARs.
Compliance with ARARs and TBCs (Continued)
Compliance with location-specific ARARs and
TBCs
No location-specific ARARs are triggered by this alternative.
No location-specific ARARs would be triggered under this alternative.
Proposed activities would be conducted in a manner consistent with coastal,
protected species, and floodplain ARAR requirements, and would be performed
so as to prevent water pollution of the nearby rivers and streams.
Compliance with action-specific ARARs and
TBCs
No actions are included in this alternative.
No action-specific ARARs are triggered by this alternative.
Construction activities would be conducted in a manner consistent with OSHA
safety regulations. Solid wastes, if generated, would be managed in accordance
with applicable state and federal handling and disposal regulations.
OBG | THERE'S A WAY
Table 11-2 Detailed Analysis of Remedial Alts-GW (FS Apr-18) (DS_mcd)R2.docx | PAGE 1 of 4
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Transportation activities would be completed in accordance with applicable state
and federal requirements, by licensed and permitted haulers. Injection of
bioremediation chemical would follow federal requirements for injection
control.
Long-Term Effectiveness and Permanence
Magnitude of residual risk
No additional actions would be implemented under Alternative
1, therefore, potential vapor intrusion risks as a result of
construction near well MW-03 would remain unless natural
attenuation reduces the concentration of TCE in groundwater to
acceptable levels.
Risk associated with vapor intrusion as a result of construction near well MW-
03 would be mitigated through institutional controls. Potential vapor
intrusion risks as a result of construction near well MW-03 would remain
unless natural attenuation reduces the concentration of TCE in groundwater
to acceptable levels.
Risk associated with vapor intrusion as a result of construction near well MW-03
would be mitigated through institutional controls until enhanced bioremediation
reduces concentrations sufficiently to eliminate the vapor intrusion risk. A
treatability study would be required to assess the long-term effectiveness of this
alternative.
Adequacy and reliability of controls
No controls are included in this alternative for protection against
vapor intrusion as a result of construction near well MW-03.
Institutional and engineering controls associated with Alternative 2 are an
adequate and reliable means of managing potential human exposures
associated with vapor intrusion near well MW-03, unless natural attenuation
reduces the concentration of TCE to acceptable levels.
Institutional and engineering controls associated with Alternative 3 would be an
adequate and reliable means of managing potential human exposures associated
with potential vapor intrusion near well MW-03, unless bioremediation reduces
the concentration of TCE to acceptable levels. A treatability study would be
required to assess the long-term effectiveness of this alternative.
Sustainability and environmental impacts
No energy consumption, greenhouse gas or pollutant emissions,
water or resource use, impacts to water, ecology, or community
are anticipated for this alternative.
No energy consumption, greenhouse gas or pollutant emissions, water or
resource use, impacts to water, ecology, or community are anticipated for
this alternative.
No long-term pollutant emissions, impacts to water, ecology, or community
would be anticipated for this alternative. Safety equipment and personal
protective equipment would protect workers from exposures. Energy
consumption and fuel use/greenhouse gas emissions would be anticipated as a
result of injection and groundwater monitoring, and would be greater than
Alternatives 1, 2, and 3.
Treatment or recycling processes employed
and materials treated
No treatment processes are used in this alternative.
No treatment processes are used in this alternative.
Application of accelerated bioremediation (reductive dechlorination) would be
applied to provide treatment and enhance natural attenuation for Site
groundwater.
Amount of hazardous substances, pollutants,
or COCs that would be treated or recycled
No treatment processes are used in this alternative.
No treatment processes are used in this alternative.
The TCE in groundwater could be treated if this alternative is effective, but data
are insufficient at this time, and assessment of the volume of contaminant
treated would be evaluated during a treatability study.
Degree of expected reduction in toxicity,
mobility, or volume
No treatment processes are used in this alternative. Natural
attenuation could result in the natural degradation of TCE over
time.
No treatment processes are used in this alternative. Natural attenuation
could result in the natural degradation of TCE over time.
Enhanced natural attenuation could potentially result in the reduction in toxicity,
mobility, and volume of impacted groundwater.
Degree to which treatment is irreversible
No treatment processes are used in this alternative. Natural
attenuation process would be irreversible.
No treatment processes are used in this alternative. Natural attenuation
process would be irreversible.
In situ treatment of groundwater is irreversible.
Type and quantity of residuals remaining after
treatment
No treatment processes are used in this alternative. Natural
attenuation could result in the natural degradation of TCE over
time.
No treatment processes are used in this alternative. Natural attenuation
could result in the natural degradation of TCE over time.
Pending results of a treatability study, enhanced in situ bioremediation is
anticipated to reduce TCE to acceptable levels in the vicinity of MW-03.
Degree to which treatment would reduce the
inherent hazards posed by the facility
No treatment processes are used in this alternative. Natural
attenuation could result in the natural breakdown of TCE over
time.
No treatment processes are used in this alternative. Natural attenuation
could result in the natural breakdown of TCE over time.
Pending results of a treatability study, enhanced in situ bioremediation is
anticipated to reduce TCE to acceptable levels in the vicinity of MW-03.
Ability of alternative to reduce the toxicity,
mobility, and volume of COCs
Alternative 1 relies on natural attenuation for reduction in
toxicity, mobility, and volume of selected COCs in groundwater.
The groundwater migration evaluation (Section 2.6.2)
performed indicates that groundwater impacted with TCE would
not impact offsite surface water and groundwater POEs.
Alternative 2 relies on natural attenuation for reduction in toxicity, mobility,
and volume of selected COCs in groundwater. The groundwater migration
evaluation (Section 2.6.2) performed indicates that groundwater impacted
with TCE would not impact offsite surface water and groundwater POEs.
Alternative 3 achieves a reduction in toxicity, mobility, and volume of COCs
through enhanced bioremediation. The groundwater migration evaluation
(Section 2.6.2) performed indicates that groundwater impacted with TCE would
not impact offsite surface water and groundwater POEs.
Short-Term Effectiveness and Impacts
Potential human exposures during
implementation of the alternative
Alternative 1 would not prevent potential human exposures
over the short term.
No treatment processes are used in Alternative 2. Instead, institutional land-
use controls would mitigate any potential human exposures to groundwater
or vapor intrusion in the short term.
Institutional land-use controls would mitigate any potential human exposures to
groundwater or vapor intrusion in the short term. Chemical hazards related to
accidental exposure groundwater COCs or bioremediation enhancement product
during groundwater treatment and/or monitoring would be managed using
proper procedures and personal protective equipment.
OBG | THERE'S A WAY
Table 11-2 Detailed Analysis of Remedial Alts-GW (FS Apr-18) (DS_mcd)R2.docx | PAGE 2 of 4
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Sustainability and environmental impacts
There are no additional short-term environmental and
sustainability impacts expected of implementing this alternative.
No energy consumption, greenhouse gas or pollutant emissions,
no water or resource use, no impacts to water, ecology,
workers, or community.
There are no additional short-term environmental and sustainability impacts
expected of implementing this alternative. No energy consumption,
greenhouse gas or pollutant emissions, no water or resource use, no impacts
to water, ecology, workers, or community.
No short-term impacts to water, ecology, or community are anticipated. Safety
equipment and personal protective equipment would protect workers from
exposures. Energy consumption and fuel use/greenhouse gas emissions would
be anticipated because of injection and groundwater monitoring, and would be
greater than Alternatives 1, 2, and 3.
Potential nuisance conditions
There would be no nuisance conditions associated with
implementing this alternative.
There would be no nuisance conditions associated with implementing this
alternative.
There would be no nuisance conditions associated with implementing this
alternative.
Engineering controls to mitigate short-term
impacts
No active components would be associated with implementing
this alternative.
No active components would be associated with implementing this
alternative.
Applicable hazards would be identified and proper health and safety measures
would be established in a project-specific HASP to be protective of workers and
the community.
Time until RAOs are achieved
With this alternative, RAOs could be met through natural
attenuation over time.
With this alternative, RAOs could be met through natural attenuation over
time.
With this alternative, groundwater RAOs would be met immediately upon
implementation of institutional controls, and could be met by bioremediation
within the treatment zone within approximately 2 years, and outside the
treatment zone could be achieved by natural attenuation over a longer time.
Technical Feasibility - ability to construct and
operate the remedial technology
Not Applicable
There would be no technologies to be constructed with this alternative.
Institutional controls are readily implementable.
Remedial elements are readily constructible and operable.
Ability to monitor effectiveness of remedy
Not Applicable
The remedy in Alternative 2 would be immediately effective upon
implementation of institutional controls and could be monitored overtime by
examining the site.
The remedy in Alternative 3 would be immediately effective upon
implementation of institutional controls and could be monitored overtime by
examining the site and performing groundwater monitoring.
Reliability of technology
Not Applicable
Not Applicable
In situ bioremediation is a reliable technology if conditions at the site are
amenable to its implementation. A treatability study would be required to
assess if it would be effective.
Ease of undertaking additional remedial
actions, if necessary
Not Applicable
If this alternative proves ineffective, additional remedial actions would be
readily implementable.
If this alternative proves ineffective, additional remedial actions would be readily
implementable.
Availability of off-site treatment storage and
disposal services and capacities
Not Applicable
Not Applicable
Not Applicable
Availability of necessary equipment,
specialists, and materials
Not Applicable
Not Applicable
Equipment, specialists, and materials for this remedy are widely available.
Potential difficulties in obtaining operation
approvals
Not Applicable
No difficulties in obtaining operation approvals would be anticipated with this
alternative.
No difficulties in obtaining operation approvals would be anticipated with this
alternative.
Total present worth capital cost
$0
$70,000
$904,424
Total present worth O&M cost
$0
$0
$297,674
Approximate total present worth project cost
$0
$70,000
$1,202,099
OBG | THERE'S A WAY
Table 11-2 Detailed Analysis of Remedial Alts-GW (FS Apr-18) (DS_mcd)R2.docx | PAGE 3 of 4
-------
Table 11-3
Cost Comparison Summary of Evaluated Alternatives
Triangle Pacific Site
Elizabeth City, North Carolina
Remedial Alternatives Cost Estimate Summary for Groundwater Alternatives
Alternatives
Total Estimated
Capital Present
Worth Cost
Total Estimated
Present Worth of
O&M (30 years)
Total
Estimated
Net Present
Alternative 1: No Further Action
$0
$0
$0
Alternative 2: Institutional Controls
$ 70,000
$0
$ 70,000
Alternative 3: Groundwater Enhanced
Bioremediation and Institutional Controls
$904,424
$297,674
$1,202,099
Remedial Alternatives Cost Estimate Summary for Soil Alternatives
Alternatives
Total Estimated
Capital Present
Worth Cost
Total Estimated
Present Worth of
O&M
Total Estimated
Net Present
Worth Cost
Alternative 1: No Further Action
$0
$0
$0
Alternative 2: Excavation and Disposal in a
Commercial Facility
$151,050
$0
$151,050
Page 1 of 1
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Table 14-1
EPA Region 4 Recommended IROD Chemical-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Chemical-Specific ARARs
Action/Media
Requirements
Prerequisite
Citation(s)
Classification of
contaminated
groundwater
Groundwaters in the state naturally containing 250 mg/L
or less of chloride are classified as GA under 15A NCAC
02L .0201(1)
Best usage: Existing or potential source of drinking water
supply for humans.
Groundwaters located within the
boundaries or under the extraterritorial
jurisdiction of the State of North Carolina
- applicable
15A NCAC 02L .0201(1)
Groundwater Classifications
Groundwaters in the state naturally containing greater
than 250 mg/L of chloride are classified as GSA under 15A
NCAC 02L .0201(2)
Best usage: Existing or potential source of water supply
for potable mineral water and conversion to fresh waters.
15A NCAC 02L .0201(2)
Restoration of
Groundwater
Shall not exceed the groundwater quality standards1 for
contaminants specified as the site related contaminants
of concern.
• Arsenic (10 ug/L)
• Chlordane (0.1 ug/L)
• Dieldrin (0.002 ug/L)
• Iron (300 ug/L)
• 1,2- Dichlorobenzene (20 ug/L)
• 1,4-Dichlorobenzene (6 ug/L)
• Trichloroethylene (3 ug/L)
• Vinyl Chloride (0.03 ug/L)
Class GA or GSA groundwaters with
contaminant(s) concentrations exceeding
standards listed in 15A NCAC 02L .0202 -
relevant and appropriate
**Due to the Interim Nature of the
Decision Document, remaining residuals
of TCE and other contaminants that
exceed 2L levels will be addressed in the
final remedy for the Site.
15A NCAC 02L .0202(a) and (b)
Groundwater Quality Standards
Shall not exceed the Safe Drinking Water Act National
Revised Primary Drinking Water Regulations: maximum
contaminant levels (MCLs) for organic contaminants
specified in 40 CFR § 141.61(a).
Groundwaters classified as GA or GSA
which are an existing or potential source
of drinking water - relevant and
appropriate
40 CFR § 141.61(a)
15A NCAC 18C .1517
1 Unless otherwise indicated, the standard refers to the total concentration in micrograms per liter of any constituent in a dissolved, colloidal or particulate form which
is mobile in groundwater. This does not apply to sediment or other particulate matter which is preserved in a groundwater sample as a result of well construction or
sampling procedures.
Page 1 of 3
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Table 14-1
EPA Region 4 Recommended IROD Chemical-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, 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.
Surface waters classified as Class SW
waters which are protected for secondary
recreation, fishing, aquatic life including
propagation and survival, and wildlife
(Newbegun Creek, Pailin Creek) -
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.
15ANCAC 02B.0208(a)(1)
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 offish (shellfish) tissue consumption,
water consumption, or other route identified as
appropriate for the water body.
• Polychlorinated biphenyls (PCBs): 0.064 ng/L
Surface waters classified as Class SW
waters which are protected for secondary
recreation and fishing - relevant and
appropriate
15A NCAC 02B.0208(a)(2),(B)(xii)
Human Health Standards
Page 2 of 3
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Table 14-1
EPA Region 4 Recommended IROD Chemical-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Chemical-Specific ARARs
Action/Media
Requirements
Prerequisite
Citation(s)
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.
Surface waters classified as Class C waters
which are protected for aquatic life
propagation, maintenance of biological
integrity, wildlife, secondary recreation,
and agriculture (Newbegun Creek, Pailin
Creek)- relevant and appropriate
15ANCAC 02B.0211(2)
Surface standards for Class C
Protection of surface
water
Numerical water quality standards (maximum permissible
levels) for the protection of human health applicable to
all fresh surface waters:
• Arsenic: 50 ug/l
• Cadmium: 0.4 ug/l
• DDT: 0.001 ug/l
• Lead: 25 ug/l
• Polychlorinated biphenyls (total of all PCBs and
congeners identified): 0.001 ug/l
Surface waters classified as Class C waters
which are protected for aquatic life
propagation, maintenance of biological
integrity, wildlife, secondary recreation,
and agriculture - relevant and
appropriate
15ANCAC 02B.0211(3)(I)
Water Quality Standards for the
Protection of Human Health
ARAR = applicable or relevant and appropriate requirement EPA = U.S. Environmental Protection Agency
CFR = Code of Federal Regulation NCAC = North Carolina Administrative Code
Page 3 of 3
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, 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.ll3A-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. 113A-52) of more than 1 acre of land -
applicable
15A NCAC 4B.0105
Managing storm water
runoff from land-
disturbing activities
con't
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.
15A NCAC 4B.0106
Page 1 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(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 ten-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 mile 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
Page 2 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
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)
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
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)
Page 3 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
load allocation for the discharge prepared by
the State and approved by EPA pursuant to 40
CFR § 130.7.
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, parameters, 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).
40 CFR § 122.45(a)
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
40 CFR § 122.45(d)(1)
Waste characterization - primary wastes (contaminated media) and secondary wastes (wastewaters, spent treatment media, etc.)
Characterization of solid
waste (all primary and
secondary wastes)
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 NCAC 13A .0106, .107
Page 4 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Must determine whether the waste is (characteristic
waste) identified in subpart C of 40 CFR part 261by
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)
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
Determinations for
management of
hazardous waste
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)
15A 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
Page 5 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
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 etseq..
This determination may be made concurrently with
the hazardous waste determination required in Sec.
262.11 of this chapter.
Generation of RCRA characteristic hazardous
waste for storage, treatment or disposal -
applicable
40 CFR § 268.9(a)
15A NCAC 13A .0112
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)
15A NCAC 13A .0112
Characterization of
industrial wastewater
Industrial wastewater discharges that are point source
discharges subject to regulation under section 402 of
the CWA, as amended, are not solid wastes for the
purpose of hazardous waste management.
[Comment: This exclusion applies only to the actual
point source discharge. It does not exclude
industrial wastewaters while they are being
collected, stored or treated before discharge, nor
does it exclude sludges that are generated by
industrial wastewater treatment.]
Generation of industrial wastewater and
discharge into surface water - applicable
40 CFR § 261.4(a)(2)
Management of PCB Waste
Management of PCB
waste
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)
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
Management of PCB
Items
Must dispose of in accordance with 40 CFR 761.60(b)
or decontaminate in accordance with 40 CFR 761.79.
Removal from use of a PCB Item containing
intact, non-leaking PCB Article - applicable
40 CFR 761.50(b)(2)
Page 6 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Must dispose of as bulk product waste in accordance
with 40 CFR 761.62(a) or (c).
Removal from use of a PCB Item where PCB
Article is no longer intact and non-leaking -
applicable
40 CFR 761.50(b)(2)
Waste Storage - primary wastes (contaminated media) 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
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);
15A NCAC 13A .0107
• 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)
15A NCAC 13A .0107
Use and management of
hazardous waste in
containers
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
Page 7 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, 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 be opened, handled and stored in
a manner that may rupture the container or cause it
to leak.
40 CFR § 265.173(a) and (b)
15A NCAC 13A .0109
Storage of hazardous
waste in container area
Area must have a containment system designed and
operated in accordance with 40 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
Page 8 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, 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 (e.g., PPE,
rags) 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)
Storage of PCB waste
and/or PCB/radioactive
waste in non-RCRA
regulated unit
Storage facility must have or be:
• Adequate roof and walls to prevent rainwater
from reaching stored PCBs and PCB items;
Storage of PCBs and PCB Items at
concentrations > 50 ppm for disposal -
applicable
40 CFR 761.65(b)(1)
40 CFR 761.65(b)(l)(i)
Page 9 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
• Adequate floor that has continuous curbing
with a minimum 6-inch high curb. Floor and
curb must provide a containment volume equal
to at least two times the internal volume of the
largest PCB article or container or 25% of the
internal volume of all articles or containers
stored there, whichever is greater.
Storage of PCB/radioactive waste as defined
in 40 CFR 761.3 - applicable
40 CFR 761.65(b)(l)(ii)
Note: 6-inch minimum curbing not required for
area storing PCB/radioactive waste;
• No drain valves, floor drains, expansion joints,
sewer lines, or other openings that would
permit liquids to flow from curbed area;
40 CFR 761.65(b)(l)(iii)
• Floors and curbing constructed of Portland
cement, concrete, or a continuous, smooth,
non-porous surface that prevents or minimizes
penetration of PCBs; and
40 CFR 761.65(b)(l)(iv)
• Not located at a site that is below the 100-year
flood water elevation.
40 CFR 761.65(b)(l)(v)
Storage area must be properly marked as required by
40 CFR 761.40(a)(10).
40 CFR 761.65(c)(3)
Storage of PCB waste
and/or PCB/radioactive
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
• is permitted by an authorized state under
RCRA §3006 and,
• PCB spills cleaned up in accordance with
Subpart G of 40 CFR 761.
Storage of PCBs and PCB Items designated for
disposal - applicable
40 CFR 761.65(b)(2)(i)-(iv)
Page 10 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Storage of
PCB/radioactive waste
in containers
For liquid wastes, containers must be nonleaking.
For non-liquid wastes, containers must be designed to
prevent buildup of liquids if such containers are
stored in an area meeting the containment
requirements of 40 CFR 761.65(b)(l)(ii); and
Storage of PCB/radioactive waste in
containers other than those meeting DOT
HMR performance standards - applicable
40 CFR 761.65(c)(6)(i)(A)
40 CFR 761.65(c)(6(i)(B)
For both liquid and non-liquid wastes, containers
must meet all regulations and requirements
pertaining to nuclear criticality safety.
40 CFR 761.65(c)(6)(i)(C)
Temporary storage of
bulk PCB remediation
waste or PCB bulk
product waste in a
waste pile
Waste must be placed in a pile that:
• is designed and operated to control dispersal
by wind, where necessary, by means other than
wetting;
• does not generate leachate through
decomposition or other reactions.
Storage of PCB remediation waste or PCB bulk
product waste at cleanup site or site of
generation for up to 180 days - applicable
40 CFR 761.65(c)(9)(i) and (ii)
Waste pile liner
performance
The storage site must have a liner designed,
constructed, and installed to prevent any migration of
wastes off or through liner into adjacent subsurface
soil, groundwater or surface water at any time during
active life (including closure period) of the storage
site.
40 CFR 761.65(c)(9)(iii)(A)
Construction of storage
pile liner
Liner must be:
• constructed of materials that have appropriate
chemical properties and sufficient strength and
thickness to prevent failure because of
pressure gradients, physical contact with waste
or leachate to which they are exposed, climatic
conditions, the stress of installation, and the
stress of daily operation;
40 CFR 761.65(c)(9)(iii)(A)(l)-(3)
Page 11 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
• 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.
Construction of 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 weather
conditions; and
40 CFR 761.65(c)(9)(iii)(B)
Construction of storage
pile run-on control
system
The storage site must have a run-on control system
designed, constructed, operated and maintained such
that it:
• prevents flow on the stored waste during peak
discharge from at least a 25-year storm;
• collects and controls at least the water volume
resulting from a 24-hour, 25-year storm.
Collection and holding facilities (e.g., tanks or basins)
must be emptied or otherwise managed expeditiously
after storms to maintain design capacity of the
system.
40 CFR 761.65(c)(9)(iii)(C) (1) and
(2)
Modification of 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).
40 CFR 761.65(c)(9)(iv)
Clean closure of TSCA
/RCRA storage facility
A TSCA/RCRA storage facility closed under RCRA is
exempt from the TSCA closure requirements of 40 CFR
761.65(e).
Closure of TSCA/RCRA storage facility —
applicable
40 CFR 761.65(e)(3)
Page 12 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Treatment/disposal of wastes - primary (contaminated media) and secondary wastes (wastewaters, spent treatment media, etc.)
Disposal of solid waste
Shall ensure that waste is disposed of at a site or
facility which is permitted to receive the waste.
Generation of solid waste intended for off-site
disposal - relevant and appropriate
15A NCAC 13B .0106(b)
Disposal of RCRA-
hazardous waste in a
land-based unit
May be land disposed if it meets the requirements in
the table "Treatment Standards for Hazardous Waste"
at 40 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
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.
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
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.
Disposal of RCRA-
hazardous waste soil in
a land-based unit
Must be treated according to the alternative
treatment standards of 40 CFR268.49(c) or according
to the UTSs [specified in 40 CFR268.48 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
Page 13 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Disposal of RCRA
wastewaters into CWA
wastewater treatment
unit
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 of 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.
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 § 268.1(c)(4)(i)
15A NCAC 13A .0112
Disposal of RCRA
characteristic
wastewaters in a POTW
Are not prohibited, if the wastes are treated for
purposes of the pre-treatment requirements of
section 307 of the CWA unless the wastes are subject
to a specified method of treatment other than DEACT
in 40 CFR §268.40, or are D003 reactive cyanide.
40 CFR § 268.1(c)(4)(ii)
15A NCAC 13A .0112
Risk-based disposal of
PCB remediation waste
May dispose of in a manner other than prescribed in
40 CFR 761.61(a) or (b) if 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.
Disposal of PCB remediation waste - relevant
and appropriate
40 CFR 761.61(c)
Performance-based
disposal of PCB bulk
product waste
May dispose of by one of the following:
• in an incinerator approved under 40 CFR
761.70;
• in a chemical waste landfill approved under 40
CFR 761.75;
• in a hazardous waste landfill permitted by EPA
under §3004 of RCRA or by authorized state
under §3006 of RCRA;
• under alternate disposal approved under 40
CFR 761.60(e);
• in accordance with decontamination provisions
of 40 CFR 761.79; or
• in accordance with thermal decontamination
provisions of 40 CFR 761.79(c)(6) for metal
surfaces in contact with PCBs.
Disposal of PCB bulk product waste as defined
in 40 CFR 761.3 - applicable
40 CFR 761.62(a)
40 CFR 761.62(a)(l)-(6)
Page 14 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Risk-based disposal of
PCB bulk product waste
May dispose of in a manner other than prescribed in
40 CFR 761.62(a) or (b) if receive approval in writing
from EPA Regional Administrator and EPA finds that
the method (based on technical, environmental or
waste specific characteristics or considerations) will
not pose an unreasonable risk of injury to human
health or the environment.
Disposal of PCB bulk product waste -
applicable
40 CFR 761.62(c)
Landfilling of solid
wastes
Prohibits disposal in a hazardous waste disposal
facility of ignitables as defined in the RCRA,
polyhalogenated biphenyls of 50 ppm or greater
concentration, and free liquids whether or not
containerized
Disposal of ignitables - applicable
NCGS 13OA- 294(h)(6)
Landfilling of solid
wastes
PCB wastes of 50 ppm or greater content are excluded
from NC landfills through waste determination and
rule
TBC
NC Division of Waste
Management, Solid Waste Section
Procedure and Criteria for Waste
Determination
Discharge of Wastewater from Groundwater Treatment Unit
Discharge into POTW
General prohibitions
A User may not introduce into a POTW any
pollutant(s) which cause Pass Through or
Interference.
These general prohibitions and the specific
prohibitions in paragraph (b) of this section apply to
each User introducing pollutants into a POTW
whether or not the User is subject to other National
Pretreatment Standards or any national, State, or
local Pretreatment Requirements.
Indirect discharge of pollutants into POTW
from Industrial User as defined 40 CFR §403.3
- applicable
40 CFR §403.5 (a)(1)
National pretreatment standards:
Prohibited discharges
15A NCAC 02H .0909
Specific prohibitions
In addition, the following pollutants shall not be
introduced into a POTW:
(1) Pollutants which create a fire or explosion hazard
in the POTW, including, but not limited to, waste
streams with a closed cup flashpoint of less than 140
degrees Fahrenheit or 60 degrees Centigrade using
the test methods specified in 40 CFR §261.21;
40 CFR §403.5 (b)(1)
15A NCAC 02H .0909
Page 15 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Discharge into POTW
co n't
Specific prohibitions
(2) Pollutants which will cause corrosive structural
damage to the POTW, but in no case Discharges
with pH lower than 5.0, unless the works is
specifically designed to accommodate such
Discharges;
Indirect discharge of pollutants into POTW
from Industrial User as defined 40 CFR §403.3
-applicable
40 CFR §403.5 (b)(2)
15A NCAC 02H .0909
(3) Solid or viscous pollutants in amounts which will
cause obstruction to the flow in the POTW resulting
in Interference;
40 CFR §403.5 (b)(3)
15A NCAC 02H .0909
(4) Any pollutant, including oxygen demanding
pollutants (BOD, etc.) released in a Discharge at a
flow rate and/or pollutant concentration which will
cause Interference with the POTW.
40 CFR §403.5 (b)(4)
15A NCAC 02H .0909
(5) Heat in amounts which will inhibit biological
activity in the POTW resulting in Interference, but in
no case heat in such quantities that the temperature
at the POTW Treatment Plant exceeds 40 °C (104 °F)
unless the Approval Authority, upon request of the
POTW, approves alternate temperature limits.
40 CFR § 403.5 (b)(5)
15A NCAC 02H .0909
(6) Petroleum oil, nonbiodegradable cutting oil, or
products of mineral oil origin in amounts that will
cause interference or pass through;
40 CFR §403.5 (b)(6)
15A NCAC 02H .0909
(7) Pollutants which result in the presence of toxic
gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and
safety problems;
40 CFR § 403.5 (b)(7)
15A NCAC 02H .0909
(8) Any trucked or hauled pollutants, except at
discharge points designated by the POTW.
40 CFR §403.5 (b)(8)
15A NCAC 02H .0909
Discharge into POTW
Con't
(d) Local limits. Where specific prohibitions or limits
on pollutants or pollutant parameters are developed
by a POTW in accordance with 40 CFR § 403.5 (c),
such limits shall be deemed Pretreatment Standards
for the purposes of section 307(d) of the CWA.
Indirect discharge of pollutants into POTW
from Industrial User as defined 40 CFR §403.3
-applicable
40 CFR § 403.5(d)
15A NCAC 02H .0909
Page 16 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Transport and
conveyance of collected
RCRA wastewater to
WWTU located on the
facility
Any dedicated tank systems, conveyance systems, and
ancillary equipment used to treat, store or convey
wastewater to an on-site NPDES-permitted
wastewater treatment unit (WWTU) are exempt from
the requirements of RCRA Subtitle C standards.
On-site wastewater treatment unit [as defined
in 40 CFR 260.10] subject to regulation under
§402 or §307(b) of the CWA (i.e., NPDES
permitted) that manages hazardous
wastewaters - applicable
40 CFR § 264.1(g)(6)
15A NCAC 13A .0109
General duty to mitigate
for discharge of WWTU
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 -
applicable
40 CFR § 122.41(d)
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 -
applicable
Technology-based
treatment requirements
for wastewater
discharge
To the extent that EPA promulgated effluent
limitations are inapplicable, State shall develop on a
case-by-case basis under § 402(a)(1)(B) of the CWA,
technology based effluent limitations by applying the
factors listed in 40 CFR § 125.3(d) and shall consider:
the appropriate technology for this category or class
of point sources; 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)
Page 17 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
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 sources(s) established under this paragraph 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 established under
§303 of the CWA - applicable
40 CFR § 122.44(d)(l)(vii)
Monitoring
requirements for
discharges from WWTU
In addition to §122.48 and to assure compliance with
effluent limitations, one must monitor, as provided in
subsections (i) thru (iv) of §122.44(i)(l).
NOTE: Monitoring parameters, including frequency
of sampling, will be developed as part of the CERCLA
process and included in a Remedial Design, Remedial
Action Work Plan, or other appropriate CERCLA
document.
Discharge of pollutants to surface waters -
applicable
40 CFR §122.44(i)(l)
All effluent limitations, standards and prohibitions
shall be established for each outfall or discharge
point, except as provided under §122.44(k)
40 CFR §122.45(a)
Groundwater
remediation
Prohibits discharges of waste into subsurface
Prohibited discharged - applicable
NCGS Chapter 143,
Article 21
Operation of Groundwater Treatment System - Air Quality
Toxic air emissions
A facility shall not emit toxic air pollutants in
quantities that may cause of contribute beyond the
premises to any significant ambient air concentrations
that may adversely affect human health.
NOTE: See Table in the cited regulation for list of
toxic air pollutants and accompanying air
concentrations
Activities potentially generating air emissions
-applicable
15ANCAC 02D.1104
Page 18 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Emission limitations for
process vents used in
treatment of VOC
contaminated
groundwater
Meet the requirements under one of the options
specified below:
• Reduce from all affected process vents the
total emissions of the HAP to a level less than
1.4 kilograms per hour (kg/hr) and 2.8 Mg/yr
(3.0 pounds per hour (Ib/hr) and 3.1 tpy);
• Reduce from all affected process vents the
emissions of total organic compounds (TOC)
(minus methane and ethane) to a level below
1.4 kg/hr and 2.8 Mg/yr (3.0 Ib/hr and 3.1 tpy);
• Reduce from all affected process vents the
total emissions of the HAP by 95 percent by
weight or more; or
• Reduce from all affected process vents the
emissions of TOC (minus methane and ethane)
by 95 percent by weight or more.
Process vents as defined in 40 CFR § 63.7957
used in site remediation of media (e.g., soil
and groundwater) that could emit hazardous
air pollutants (HAP) listed in Table 1 of
Subpart GGGGG of Part 63 and vent stream
flow exceeds the rate in 40 CFR §
63.7885(c)(1) - relevant and appropriate.
40 CFR § 63.7890(b)(l)-(4)
15A NCAC02D .1110
Standards for closed
vent systems and
control devices used in
treatment of VOC
contaminated
groundwater
For each closed vent system and control device you
use to comply with the requirements above, you must
meet the operating limit requirements and work
practice standards in Sec. 63.7925(d) through (j) that
apply to the closed vent system and control device.
NOTE: EPA approval to use alternate work practices
under paragraph (j) in 40 CFR § 63.7925 will be
obtained in a CERCLA document.
Closed vent system and control devices as
defined in 40 CFR § 63.7957 that are used to
comply with § 63.7890(b) - relevant and
appropriate.
40 CFR § 63.7890(c)
15ANCAC 02D.1110
Monitoring of closed
vent systems and
control devices used in
treatment of VOC
contaminated
groundwater
Must monitor and inspect the closed vent system and
control device according to the requirements in 40
CFR § 63.7927 that apply to the affected source.
NOTE: Monitoring program will be developed as part
of the CERCLA process and included in an
appropriate CERCLA document.
Closed vent system and control devices as
defined in 40 CFR § 63.7957 that are used to
comply with § 63.7890(b) - relevant and
appropriate.
40 CFR § 63.7892
15ANCAC 02D.1110
Page 19 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Groundwater Remediation Wells - Air injection wells, extraction wells, re-injection wells and UIC wells for additives (e.g., ISCO)
General standard for
recovery well (e.g.,
multi-phase extraction
well)
Recovery wells shall be located, designed,
constructed, operated and abandoned with materials
and by methods which are compatible with the
chemical and physical properties of the contaminants
involved, specific site conditions and specific
subsurface conditions.
Design, construction, or operation of any
recovery well - applicable
15A NCAC 02C .0108(c)
Recovery well boreholes shall not penetrate to a
depth greater than the depth to be monitored or the
depth from which contaminants are to be recovered.
Any portion of the borehole that extends to a depth
greater than the depth to be monitored or the depth
from which contaminants are to be recovered shall be
grouted completely to prevent vertical migration of
contaminants.
15A NCAC 02C .0108(d)
Standards for pumps
and equipment for
extraction well
The pumping capacity of the pump shall be consistent
with the intended use and yield characteristics of the
well.
Design, construction, or operation of any
extraction well (not used for water supply) -
applicable
15A NCAC 02C .0109(a)
The pump and related equipment for the well shall be
located to permit easy access and removal for repair
and maintenance.
15A NCAC 02C .0109(b)
The base plate of a pump placed directly over the well
shall be designed to form a watertight seal with the
well casing or pump foundation.
15A NCAC 02C .0109(c)
In installations where the pump is not located directly
over the well, the annular space between the casing
and pump intake or discharge piping shall be closed
with a watertight seal.
15ANCAC 02C .0109(d)
The well head shall be equipped with a screened vent
to allow for the pressure changes within the well
except if a suction lift pump or single-pipe jet pump is
used or artesian, flowing well conditions are
encountered.
15A NCAC 02C .0109(e)
Page 20 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
A priming tee shall be installed at the well head in
conjunction with offset jet pump installations.
15A NCAC 02C .0109(g)
Standards for pumps
and equipment for
extraction well con't
Joints of any suction line installed underground
between the well and pump shall be tight under
system pressure.
Design, construction, or operation of any
extraction well (not used for water supply) -
applicable
15ANCAC 02C .0109(h)
The drop piping and electrical wiring used in
connection with the pump shall meet all applicable
underwriter's specifications.
15ANCAC 02C ,0109(i)
Design criteria for all
injection wells
No person shall construct, operate, maintain, convert,
plug, abandon, or conduct any other injection activity
in a manner that allows the movement of fluid
containing any contaminant into underground sources
of drinking water if the presence of that contaminant
may cause a violation of any applicable groundwater
quality standard specified in Subchapter 02L or may
otherwise adversely affect human health.
Design, construction, or operation of any
injection well - applicable
40 CFR § 144.12
15A NCAC 02C.0211(c)
Injection of substances
into underground well
Groundwater remediation wells used to inject
additives, treated groundwater, or ambient air for
treatment of contaminated soil or groundwater may
inject only additives determined by Department of
Health and Human services not to adversely affect
human health.
Injection of fluids into or air into an underground
well for the purposes of groundwater
remediation - applicable
15ANCAC 02C .0225(a)
Rule requirements for other wells shall be treated as
one of the injection well types in Rule .0209(5)(b) that
most closely resembles the equivalent hydrogeologic
complexity and potential to adversely affect
groundwater quality.
Injection of substances into an underground
well other than liquids or air - TBC
15A NCAC 02C .0230
The Director may permit by rule the emplacement or
discharge of a fluid or solid into the subsurface for any
activity that meets the definition of an "injection well"
that the Director determines not to have the potential
to adversely affect groundwater quality and does not
fall under other rules in this Section.
Page 21 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Multi-screened wells shall not connect aquifers or
zones having differences in water quality which would
result in a degradation of any aquifer or zone.
15ANCAC 02C.0225(g)(17)
Reinjection of treated
contaminated
groundwater
Wells are not prohibited if injection is approved by
EPA or a State pursuant to provisions for cleanup of
releases under CERCLA or RCRA as provided in the
CERCLA document.
Class IV wells [as defined in 40 CFR § 144.6(d)]
used to re-inject treated contaminated
groundwater into the same formation from
which it was drawn - relevant and appropriate
40 CFR § 144.13(c)
RCRA § 3020(b)
Construction of air
injection well [as
defined in 15A NCAC
02C.0224(2)]
The air injected shall not exceed ambient air quality
standards set forth in 15A NCAC 02D.0400 and shall
not contain petroleum or any constituent that would
cause a violation of groundwater standards specified
in Subchapter 02L.
Shall be constructed in accordance with the well
construction standards applicable to monitoring wells
specified in Rule .0108 of this Subchapter.
Installation of groundwater remediation wells
for the subsurface injection of ambient air for
the treatment of contaminated soil or
groundwater (permitted by Rule)- applicable
15A NCAC 02C.0225(b)(4)(A) and
(B)
Injection zone
determination
Shall specify the horizontal and vertical portion of the
injection zone within which the proposed injection
activity shall occur based on the hydraulic properties
of that portion of the injection zone specified.
No violation of groundwater quality standards
specified in Subchapter 02L resulting from the
injection shall occur outside the specified portion of
the injection zone as detected by a monitoring plan
approved by the Division.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(e)(2)
Page 22 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Location of groundwater
remediation wells
Wells shall not be located where:
(A) surface water or runoff will accumulate around
the well due to depressions, drainage ways, or other
landscapes that will concentrate water around the
well;
(B) a person would be required to enter confined
spaces to perform sampling and inspection activities;
and
(C) injectants or formation fluids would migrate
outside the approved injection zone as determined by
the applicant in accordance with Subparagraph (e)(2)
of this Rule.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15ANCAC 02C.0225(g)(l)
Construction of
remediation wells
The methods and materials used in construction shall
not threaten the physical and mechanical integrity of
the well during its lifetime and shall be compatible
with the proposed injection activities.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(3)
The well shall be constructed in such a manner that
surface water or contaminants from the land surface
cannot migrate along the borehole annulus either
during or after construction.
15A NCAC 02C.0225(g)(4)
The borehole shall not penetrate to a depth greater
than the depth at which injection will occur unless the
purpose of the borehole is the investigation of the
geophysical and geochemical characteristics of an
aquifer. Following completion of the investigation the
borehole beneath the zone of injection shall be
grouted completely to prevent the migration of any
contaminants.
15A NCAC 02C.0225(g)(5)
Page 23 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
Grouted Wells
Only allowable grout listed under Rule .0107 of this
Subchapter shall be used with the exception that
bentonite grout shall not be used:
(A) to seal zones of water with a chloride
concentration of 1,500 milligrams per liter or greater
as determined by tests conducted at the time of
construction, or
(B) in areas of the State subject to saltwater intrusion
that may expose the grout to water with a chloride
concentration of 1,500 milligrams per liter or greater
at any time during the life of the well.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(8)
Grouted Wells
The annular space between the borehole and casing
shall be grouted:
(A) with a grout that is non-reactive with the casing or
screen materials, the formation, or the injectant;
(B) from the top of the gravel pack to land surface and
in such a way that there is no interconnection of
aquifers or zones having differences in water quality
that would result in degradation of any aquifer or
zone; and
(C) so that the grout extends outward from the casing
wall to a minimum thickness equal to either one-third
of the diameter of the outside dimension of the casing
or two inches, whichever is greater; but in no case
shall a well be required to have an annular grout seal
thickness greater than four inches.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(9)
Page 24 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
Grouted Wells
Grout shall be emplaced around the casing by one of
the following methods:
(A) Pressure. Grout shall be pumped or forced under
pressure through the bottom of the casing until it fills
the annular space around the casing and overflows at
the surface;
(B) Pumping. Grout shall be pumped into place
through a hose or pipe extended to the bottom of the
annular space which can be raised as the grout is
applied. The grout hose or pipe shall remain
submerged in grout during the entire application; or
(C) Other. Grout may be emplaced in the annular
space by gravity flow in such a way to ensure
complete filling of the space. Gravity flow shall not be
used if water or any visible obstruction is present in
the annular space at the time of grouting.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(10)
Grouted Wells
All grout mixtures shall be prepared prior to
emplacement per the manufacturer's directions with
the exception that bentonite chips or pellets may be
emplaced by gravity flow if water is present or
otherwise hydrated in place.
If an outer casing is installed, it shall be grouted by
either the pumping or pressure method.
The well shall be grouted within seven days after the
casing is set or before the drilling equipment leaves
the site, whichever occurs first.
No additives that will accelerate the process of
hydration shall be used in grout for thermoplastic well
casing.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(ll)- (14)
Page 25 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
Well casings
A casing shall be installed that extends from at least
12 inches above land surface to the top of the
injection zone.
Wells with casing extending less than 12 inches above
land surface and wells without casing may be
approved when one of the following conditions is
met:
(A) site specific conditions directly related to business
activities, such as vehicle traffic, would endanger the
physical integrity of the well; or
(B) it is not operationally feasible for the well head to
be completed 12 inches above land surface due to the
engineering design requirements of the system.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(15) and
(16)
Prior to removing the equipment from the site, the
top of the casing shall be sealed with a water-tight cap
or well seal, as defined in G.S. 87-85, to preclude
contaminants from entering the well.
15ANCAC 02C.0225(g)(18)
Gravel and sand
packed wells
Packing materials for gravel and sand packed wells
shall be:
(A) composed of quartz, granite, or other hard, non-
reactive rock material;
(B) clean, of uniform size, water-washed and free
from clay, silt, or other deleterious material;
(C) disinfected prior to subsurface emplacement;
(D) emplaced such that it shall not connect aquifers or
zones having differences in water quality that would
result in the deterioration of the water qualities in any
aquifer or zone; and
(E) evenly distributed around the screen and shall
extend to a depth at least one foot above the top of
the screen. A minimum one-foot thick seal comprised
of bentonite clay or other sealing material approved
by the Director shall be emplaced directly above and
in contact with the packing material.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15ANCAC 02C.0225(g)(19)
Page 26 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
A hose bibb, sampling tap, or other collection
equipment approved by the Director shall be installed
on the line entering the injection well such that a
sample of the injectant can be obtained immediately
prior to its entering the injection well.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(21)
If applicable, all piping, wiring, and vents shall enter
the well through the top of the casing unless
otherwise approved by the Director based on a design
demonstrated to preclude surficial contaminants from
entering the well.
15A NCAC 02C.0225(g)(22)
Construction of
remediation wells con't
Well head
The well head shall be completed in such a manner so
as to preclude surficial contaminants from entering
the well and well head protection shall include:
(A) an accessible external sanitary seal installed
around the casing and grouting; and
(B) a water-tight cap or seal compatible with the
casing and installed so that it cannot be removed
without the use of hand or power tools.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(g)(23)
Unless permitted by this rule, pressure at the well
head shall be limited to a maximum which will ensure
that the pressure in the injection zone does not
initiate new fractures or propagate existing fractures
in the injection zone, initiate fractures in the confining
zone, or cause the migration of injected or formation
fluids outside the injection zone or area.
Injection between the outermost casing and the well
borehole is prohibited.
Monitoring of the operating processes at the well
head shall be provided for by the well owner, as well
as protection against damage during construction and
use.
15A NCAC 02C.0225(i)(l)-(3)
Page 27 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Mechanical integrity of
wells
All permanent injection wells require tests for
mechanical integrity, which shall be conducted in
accordance with Rule .0207 of this Section.
An injection well has internal mechanical integrity
when there is no leak in the casing, tubing, or packer.
An injection well has external mechanical integrity
when there is no fluid movement into groundwaters
through vertical channels adjacent to the injection
well bore.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15ANCAC 02C.0225(h)
15A NCAC 0207(a) and (b)
Operation and
maintenance of
treatment system
Shall at all times properly operate and maintain all
facilities and systems of treatment and control (and
related appurtenances) which are installed or used.
Proper operation and maintenance includes effective
performance and adequate laboratory and process
controls, including appropriate quality assurance
procedures.
Operation of a well for injection of additives or
groundwater underground - applicable
15A NCAC 02C .0211(k)
Monitoring of injection
wells
Monitoring wells shall be of sufficient quantity and
location so as to detect any movement of injection
fluids, injection process byproducts or formation
fluids outside the injection zone as determined by the
applicant in accordance with Subparagraph (e)(2) of
this Rule. The monitoring schedule shall be consistent
with the proposed injection schedule, pace of the
anticipated reactions, and rate of transport of the
injectants and contaminants.
NOTE: The Monitoring will be specified in a
monitoring plan included as part of a CERCLA
document (e.g., Remedial Design or Remedial Action
Work Plan).
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - applicable
15A NCAC 02C.0225(e)(9)
Page 28 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Monitoring of injection
wells con't
If affected, may require additional monitor wells
located to detect any movement of injection fluids,
injection process byproducts, or formation fluids
outside the injection zone as determined by the
applicant in accordance with Subparagraph (e)(2) of
this Rule.
If the operation is affected by subsidence or
catastrophic collapse, the monitoring wells shall be
located so that they will not be physically affected and
shall be of an adequate number to detect movement
of injected fluids, process byproducts, or formation
fluids outside the injection zone or area.
Installation of monitoring wells in (or adjacent
to) the injection zone that may be affected by
injection operations - applicable
15A NCAC 02C.0225(j)(3)
Monitoring Well Installation, Operation, and Abandonment
Implementation of
groundwater monitoring
system
Must install and implement a monitoring system to
evaluate the effects of the discharge upon waters of
the state, including the effect of any actions taken to
restore groundwater quality, and the efficiency of any
treatment facility.
NOTE: The Monitoring will be specified in a
monitoring plan included as part of a CERCLA
document (e.g., Remedial Design or Remedial
Action Work Plan).
Groundwater remediation activities -
applicable
15ANCAC 02L .0110(a)
Shall be constructed in a manner that will not result in
contamination of adjacent groundwaters of a higher
quality.
Installation of monitoring system to evaluate
effects of any actions taken to restore
groundwater quality, as well as the efficacy of
treatment - applicable
15ANCAC 02L .0110(b)
Construction of
groundwater monitoring
well(s)
No well shall be located, constructed, operated, or
repaired in any manner that may adversely impact the
quality of groundwater.
Installation of wells (including temporary
wells, monitoring wells) other than for water
supply-applicable
15A NCAC 02C .0108(a)
Page 29 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
groundwater monitoring
well(s) con't
Shall be located, designed, constructed, operated and
abandoned with materials and by methods which are
compatible with the chemical and physical properties
of the contaminants involved, specific site conditions,
and specific subsurface conditions.
Installation of wells (including temporary
wells, monitoring wells) other than for water
supply-applicable
15A NCAC 02C .0108(c)
Monitoring well and recovery well boreholes shall not
penetrate to a depth greater than the depth to be
monitored or the depth from which contaminants are
to be recovered. Any portion of the borehole that
extends to a depth greater than the depth to be
monitored or the depth from which contaminants are
to be recovered shall be grouted completely to
prevent vertical migration of contaminants.
15ANCAC 02C .0108(d)
Shall be constructed in such a manner as to preclude
the vertical migration of contaminants with and along
borehole channel.
15A NCAC 02C .0108(f)
The well shall be constructed in such a manner that
water or contaminants from the land surface cannot
migrate along the borehole annulus into any packing
material or well screen area.
15A NCAC 02C .0108(g)
Construction of
groundwater monitoring
weli(s) con't
Packing material placed around the screen shall
extend at least one foot above the top of the screen.
Unless the depth of the screen necessitates a thinner
seal, a one-foot thick seal, comprised of chip or pellet
bentonite or other material approved by the
Department as equivalent, shall be emplaced directly
above and in contact with the packing material.
Installation of wells (including temporary
wells, monitoring wells) other than for water
supply - applicable
15ANCAC 02C .0108(h)
Page 30 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Grout shall be placed in the annular space between
the outermost casing and the borehole wall from the
land surface to the top of the bentonite seal above
any well screen or to the bottom of the casing for
open end wells. The grout shall comply with
Paragraph (e) of Rule .0107 of this Section except that
the upper three feet of grout shall be concrete or
cement grout.
15ANCAC 02C ,0108(i)
All wells shall be grouted within seven days after the
casing is set. If the well penetrates any water-bearing
zone that contains contaminated or saline water, the
well shall be grouted within one day after the casing is
set.
15ANCAC 02C .01080
Construction of
groundwater monitoring
well(s) con't
Shall be secured with a locking well cap to ensure
against unauthorized access and use.
Shall be equipped with a steel outer well casing or
flush-mount cover, set in concrete, and other
measures sufficient to protect the well from damage
by normal site activities.
Installation of wells (including temporary
wells, monitoring wells) other than for water
supply - applicable
15A NCAC 02C .0108(k) and (1)
The well casing shall be terminated no less than 12
inches above land surface unless all of the following
conditions are met:
(1) site-specific conditions directly related to business
activities, such as vehicle traffic, would endanger the
physical integrity of the well; and
(2) the well head is completed in such a manner so as
to preclude surficial contaminants from entering the
well.
15ANCAC 02C ,0108(n)
Page 31 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Construction of
groundwater monitoring
well(s) con't
Shall have permanently affixed an identification plate.
The identification plate shall be constructed of a
durable, waterproof, rustproof metal or other
material approved by the Department as equivalent
and shall contain the following information:
(1) well contractor name and certification number;
(2) date well completed;
(3) total depth of well;
(4) a warning that the well is not for water supply and
that the groundwater may contain hazardous
materials;
(5) depth(s) to the top(s) and bottom(s) of the
screen(s); and
(6) the well identification number or name assigned
by the well owner.
Installation of wells (including temporary
wells, monitoring wells) other than for water
supply - applicable
15A NCAC 02C ,0108(o)
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.
15A NCAC 02C ,0108(p)
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)
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)
Maintenance of
groundwater monitoring
well(s) con't
Broken, punctured, or otherwise defective or
unserviceable casing, screens, fixtures, seals, or any
part of the well head shall be repaired or replaced, or
the well shall be abandoned pursuant to 15A NCAC
02C.0113
Installation of wells (including temporary
wells and monitoring wells) other than for
water supply - applicable
15ANCAC 02C .0112(d)
Page 32 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
All materials used in the maintenance, replacement,
or repair of any well shall meet the requirements for
new installation.
15A NCAC 02C .0112(c)
No well shall be repaired or altered such that the
outer casing is completed less than 12 inches above
land surface. Any grout excavated or removed as a
result of the well repair shall be replaced in
accordance with Rule .0107(f) of this Section.
15A NCAC 02C .0112(f)
Abandonment of
groundwater monitoring
and remediation well(s)
Shall be abandoned by filling the entire well up to land
surface with grout, dry clay, or material excavated
during drilling of the well and then compacted in
place; and
Permanent abandonment of wells (including
temporary wells, monitoring wells, and test
borings) other than for water supply less than
20 feet in depth and which do not penetrate
the water tabl - applicable
15ANCAC 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
15ANCAC 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)
Transportation of Wastes - Primary and Secondary Wastes
Transportation of
hazardous materials
Shall be subject to and must comply with all
applicable provisions of the HMTA and HMR at 49 CFR
171-180.
Any person who, under contract with a
department or agency of the federal
government, transports "in commerce," or
causes to be transported or shipped, a
hazardous material - applicable
49 CFR § 171.1(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
Page 33 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Transportation of
hazardous waste on-site
The generator manifesting requirements of 40 CFR
Sect. 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
Transportation of PCB
wastes off-site
Must comply with the manifesting provisions at 40
CFR 761.207 through 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, under contract with a
department or agency of the federal
government, transports "in commerce," or
causes to be transported or shipped, a
hazardous material - applicable
49 CFR 171.1(c)
Institutional Controls for Contamination Left in Place
Notice of Contaminated
Site
Prepare and certify by professional land surveyor a
survey plat which identifies contaminated areas which
shall be entitled "NOTICE OF CONTAMINATED SITE".
Notice shall include a legal description of the site that
would be sufficient as a description in an instrument
of conveyance and meet the requirements of NCGS
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
NCGS 143B-279.10(a)
Page 34 of 35
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Table 14-2
EPA R4 Legal Recommended IROD Action-Specific ARARs
Triangle Pacific Corp. Superfund Site, Elizabeth City, North Carolina
Action-Specific ARARs
Action
Requirements
Prerequisite
Citation(s)
Notice of Contaminated
Site con't
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.
NCGS 143B-279.10(a)(l)-(3)
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.
NCGS 143B-279.10(b) and (c)
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
NCGS 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
NCAC = North Carolina Administrative Code
N.C.G.S = North Carolina General Statutes
NPDES = National Pollutant Discharge Elimination System
POTW = Publicly Owned treatment Works
HMR = Hazardous Materials Regulations
HMTA = Hazardous Materials Transportation Act
RCRA = Resource Conservation and Recovery Act of 1976
TBC = to be considered
UTS = Universal Treatment Standard
WWTU = waste water treatment unit
Page 35 of 35
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Table 14-3
EFA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(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 l.(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
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 G.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
15ANCAC 026.0230(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
Activities within, wetlands as defined by G.S.
143-212(6) - applicable
15ANCAC 02B.0231(b)(l)-(3)
Page 1 of 5
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Table 14-3
EFA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
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;
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)
Determination that wetlands
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
Discharge to Class WL wetlands, as defined at
15A NCAC 2B .0101(c)(8) - applicable
15A NCAC 02H .0506(b)
Page 2 of 5
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Table 14-3
EFA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
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 NCDEQand the USACE, as appropriate and
documented in CERCLA Remedial Design or Remedial
Action Work Plan.
Coastal Zone
Coastal Management: State Guidelines for Areas of
Environmental Concern: Coastal Wetlands, The Estuarine
and Ocean Systems, Natural and Cultural Resource Areas,
Development Standards Applicable to All AECs
TBC
15A NCAC 7H, M
NC Coastal Management Act
Floodplains
Presence of Floodplains
designated as such on a map1
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
Executive Order 11988
Section 2.(a)(2) Floodplain
Management
1 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.
Page 3 of 5
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Table 14-3
EFA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
potential harm to or within the floodplain
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
minimize2 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
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 actions3
from the 500-year flood;
• Potential adverse impacts that action may have on
floodplain values.
44 CFR § 9.11(c)(1) 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 13 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
Presence of federally
Endangered and Threatened
species listed in 50 CFR
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
Agency action that may jeopardize listed
wildlife species, or destroy or adversely
16 U.S.C. §1536 (a)(2)
-or Section 7(a)(2) of the
Endangered Species Act of
2 Minimize means to reduce to smallest amount or degree possible. See 44 CFR § 9.4 Definitions.
3 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.
Page 4 of 5
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Table 14-3
EFA Region 4 Legal Recommended IROD Location-Specific ARARs and TBCs
Triangle Pacific Superfund Site, Elizabeth City, North Carolina
Location-Specific ARARs and TBCs
Location
Requirements
Prerequisite
Citation(s)
17.11(h) - or critical habitat
of such species listed in 50
CFR § 17.95
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.
modify critical habitat - applicable
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)
ARAR = applicable or relevant and appropriate requirement
CFR = Code of Federal Regulations
CWA = Clean Water Act of 1972
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
PCB = polychlorinated biphenyl
TBC = to be considered
USACE = U.S. Army Corps of Engineers
U.S.C. = United States Code
Page 5 of 5
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Table 14-4
Cost Effectiveness Matrix
Triangle Pacific Site
Elizabeth City, North Carolina
Relevant Considerations for Cost Effectiveness Determination
Alternative
Cost
Effective?
Present
Worth Cost
Long-Term Effectiveness
and Permanence
Reduction of Toxicity,
Mobility, and Volume
Through Treatment
Short-Term Effectiveness
Surface Soil
1 - No Action
Nol
$0
Soils acting as continuing
source of contamination to
the underlying groundwater
Minimal reduction on
Toxicity, Mobility, and
Volume
Soils acting as continuing source of
contamination to the underlying
groundwater
2 - Excavation and Off-Site
Disposal
Yes
$ 151,050
Major reduction in soils
continuing to adversely
impact quality of underlying
groundwater
Major reduction in Toxicity,
Mobility, and Volume
Major reduction in soils continuing to
adversely impact quality of underlying
groundwater
Groundwater
1 - No Action
Nol
$0
No appreciable reduction in
Long-Term risk
Minimal reduction on
Toxicity, Mobility, and
Volume
Continued Risk to hypothetical future
resident living on the property and/or
commercial/ industrial worker working on
the property
2 - Institutional Controls
Yes
$ 70,00
Reduction in long-term risk
Minimal reduction on
Toxicity, Mobility, and
Volume
Controlled Exposure of contaminants in
groundwater resulting in unacceptable risks
to hypothetical future resident living on the
property and/or commercial/ industrial
worker working on the property
3 - Enhanced
Bioremediation and
Institutional Controls
Yes
$1,202,099
Reduction in long-term risk
Reduces Toxicity, Mobility,
and Volume of contaminants
in through mineralization of
contaminants by microbes in
the groundwater
Eventual elimination of contaminants in
groundwater resulting in unacceptable risks
to hypothetical future resident living on the
property and/or commercial/ industrial
worker working on the property
Notes:
1 - This alternative does not reduce risks to human health and therefore is not considered cost effective
Page 1 of 1
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APPENDIX C
Interim Proposed Plan
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&z.
INTERIM ACTION PROPOSED PLAN
TRIANGLE PACIFIC
Elizabeth City, North Carolina
April 2018
You are Invited to Comment on this Proposed Cleanup for the Triangle Pacific Site, Elizabeth City, NC
Community Involvement
Coordination
Public Comment Period
Dates: May 8 through June 7, 2018
Purpose: To solicit comments on the Proposed
Cleanup Plan
Public Meeting
Date: May 8, 2018
Time: 6:00 to 8:00 PM
Place: Pasquotank-Camden Library
100 East Colonial Avenue
Elizabeth City, NC 27909
Purpose: As part of public involvement during the
public comment period, the community is invited to a
public meeting. EPA will present its understanding of
the site, describe its reasoning for the Preferred
Alternative presented in this Proposed Plan, and
answer questions from the community. Oral and
written comments also will be accepted at the public
meeting.
Jon Richards
Remedial Project Manager
U.S. Environmental Protection Agency
Phone: (404) 562-8648
Facsimile: (404)562-8816
E-mail: Richards.Jon@epa.gov
Triangle Pacific Site Information Repository
Pasquotank-Camden Library
100 East Colonial Avenue
Elizabeth City, NC 27909
Phone: (252) 335-2473
Hours: Mon, Wed, & Fri: 8:30 a.m. - 6:30 p.m.
Tue & Thu: 8:30 a.m. - 7:00 p.m.
Sat: 10:00 a.m. - 2:00 p.m.
1. INTRODUCTION
This Proposed Plan presents the U.S.
Environmental Protection Agency's (EPA) Preferred
Alternative and provides the rationale for an interim
action to address contaminated soil and
groundwater at the Triangle Pacific Corporation
Site (Site) in Elizabeth City, North Carolina. This
proposed plan also includes summaries of other
remedial alternatives evaluated in the 2018
Feasibility Study (FS). The purpose of this interim
remedial action is to address the most elevated
contaminant concentrations in soil and
groundwater. After implementation of the interim
remedy, the EPA will gather additional information
to determine how best to address residual Site
contamination. Any residual contamination
presenting unacceptable risk to human health or
the environment will be addressed in the final
remedy for the Site.
The EPA, in consultation with the North Carolina
Department of Environmental Quality (NCDEQ) will
select an interim remedial action for the Site after
reviewing and considering all information submitted
during the public comment period. The EPA, in
consultation with NCDEQ, may modify the
Preferred Alternative or select another response
action presented in this Proposed Plan based on
new information or public comments. Therefore, the
public is encouraged to review and comment on all
of the alternatives presented in this Proposed Plan.
The EPA, the lead agency, in consultation with the
NCDEQ, is issuing this Proposed Plan as part of its
public participation responsibilities under Section
117(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLAor Superfund), of 1980, as amended by
the Superfund Amendments and Reauthorization
Act of 1986, and Section 300.435(f)(2) of the
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This Proposed Plan
summarizes and identifies key information that can
be found in greater detail in the Remedial
Investigation [RI/FS] and other documents
contained in the Administrative Record file for this
Site. The EPA and the NCDEQ encourage the
public to review these documents to gain a more
comprehensive understanding of the Site and
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Superfund activities planned and being conducted
there. The Administrative Record and Information
Repository can be found in both the Pasquotank-
Camden Library located at 100 East Colonial
Avenue, Elizabeth City, NC and in EPA's, Region 4
Information Center at 61 Forsyth Street, Sam Nunn
Atlanta Federal Center, Atlanta, Georgia.
To ensure the community's concerns are being
addressed, a public comment period lasting 30
calendar days will be held. During this time the
public is encouraged to submit comments to EPA
on this Proposed Plan. EPA will also hold a public
meeting at 6:00 p.m. on Tuesday, May 8, 2018, at
the Pasquotank-Camden Library located at 100
East Colonial Avenue, Elizabeth City, NC 27909.
Comments can also be submitted through the mail,
via facsimile, or email. Please see the text box
entitled, "Community Involvement Coordination" for
additional details on community participation.
2. SCOPE AND ROLE
The Triangle Pacific Corporation Site is not on the
National Priorities List (NPL)f. The EPA is;
however, managing the Site as a "NPL-equivalent"
site and is following the CERCLA remedial process.
The Site is being addressed as a single operable
unit. The EPA is proposing an interim action to
address two areas with elevated soil contamination
prior to completion of a site-wide ecological risk
assessment [see Fig 3], Any remaining residual soil
contamination after this interim remedy still
presenting unacceptable ecological risk will be
addressed in the final remedy for the Site.
Groundwater beneath the Site is classified as
current and potential sources of drinking water. The
EPA is proposing an interim action to address the
volatile organic compound (VOC [Trichloroethene
[TCE]) contaminant mass within the groundwater
plume prior to completion of the groundwater
investigation. After the bioremediation treatment
remedy [selected for this interim remedy], any
1 The National Priorities List (NPL) is the list of sites of
national priority among the known releases or
threatened releases of hazardous substances,
pollutants, or contaminants throughout the United States
and its territories. The NPL is intended primarily to guide
the EPA in determining which sites warrant further
investigation.
remaining residual TCE or other COCs in
groundwater contamination presenting
unacceptable risk or above federal or state drinking
water standards will be addressed in the final
remedy for the site.
The current and reasonably anticipated future use
for the majority of the Site is industrial. Should land
use change, further investigation, a supplemental
human health risk assessment, and additional
response actions may be required.
The southern portion of the Site where the Landfill
is located is zoned for residential use, and is
expected to be rezoned for commercial use before
the final ROD.
3. SITE BACKGROUND AND HISTORY
The 188-acre Triangle Pacific Corporation Site is
located at 1268 Toxey Road, approximately 5.5
miles southeast of Elizabeth City, in Pasquotank,
North Carolina (NC). The Site is situated on the
southern portion of a small peninsula formed by the
Pasquotank River on the east and Newbegun
Creek on the south. A small tributary of Newbegun
Creek called Pailin Creek borders a portion of the
west side of the Site. The surrounding area
consists of residential communities, but is mostly
agricultural.
In 1943, the United States Government acquired
the land containing the Site, which the Navy
subsequently developed and operated as a dirigible
(lighter-than-air craft or "blimp") Weeksville Naval
Air Station base and used the site for seaplane
maintenance and repair. The Navy continued its
operations at the Weeksville Naval Air Station until
1960. During the dirigible base operations, the
Navy constructed two large the hangars to facilitate
the construction and testing of the aircraft. One of
the hangers is still standing and located on the Site.
In 1964, the United States Government sold the
parcel containing the Site to the North Carolina
State Port Authority, who in turn, sold the pa reel to
Westinghouse in 1967. Westinghouse thereafter
sold the majority of the base, retaining what is now
referred to as the "Site" for its use for the
manufacture of wooden kitchen and bathroom
cabinets. Westinghouse converted the former
hangar into its manufacturing plant. In 1977,
Westinghouse sold its cabinet-making business,
including the Site, to Triangle Pacific Corporation,
2
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which continued to manufacture cabinets at the Site
until 1996. Triangle Pacific Corporation then sold
most of the property to TCOM LP (TCOM), who
now manufactures and tests aerostat launching
systems. TCOM has sold a portion of the Site to
Rankin Real Estate, who leases it to AMS
Corporation for use in the deployment of airship
advertising.
From 1975 to 1996 the site is known to have
generated two separate hazardous waste streams
from the manufacturing of wooden cabinets, as well
as one non-hazardous waste stream. The waste
streams were created from spent non-halogenated
solvent based toner and lacquer thinner and
lacquer dust. The toner and lacquer thinner
reportedly contained various chemicals including
methyl ethyl ketone, toluene, acetone, isobutanol
and several metals including cadmium and arsenic.
From 1996 to the present, much of the Site is
unused by the current owners TCOM LP (TCOM),
and most of the current operations are
concentrated on the northeastern portion of the Site
(Figure 1). The Site is dominated by a hangar
building, which is used by TCOM for office space,
storage, and inflation of aerostats. To the north
and east of the hangar are concrete aprons that
represent former taxiways and runways constructed
by the Navy and currently used by TCOM for
equipment storage, parking, and testing of aerostat
systems.
Across the street to the west of the hangar and
north of the main access road is a building TCOM
currently uses for the assembly and testing of
launching platforms for aerostats. This building
was constructed in 2009, and overlies the former
manufacturing building (Building 402), and drum
storage pad, which was located to the west of this
building. Further to the west of the hangar is
another building, primarily used by AMS
Corporation as office and storage space. West of
the hangar and to the south of the main access
roads are a number of older structures, including a
water tower, former cistern, boiler house, and
former public works shop building and fueling
station. The water tower and fueling station are
currently used by TCOM. The former cistern is
used for storage by TCOM.
The boiler house is not in use and is overgrown
with vegetation and in poor condition. The area to
the south of the boiler house is a former coal
storage area. The area has a low mound of coal
remnants and soil and is overgrown with
vegetation. The former public works shop building
is currently used for storage by TCOM. The area
north of the former public works shop building is a
concrete apron with abandoned pipe penetrations.
This area formerly contained a fire station, a
transportation shop, and a public works garage, as
well as a waste oil tank. Within the overgrown area
south of the former public works shop building Is
the foundation of a former laundry building. To the
west of the former laundry building is a concrete
apron and equipment pad. The apron is contiguous
with the foundation for the public works storage
building, and formerly contained the public works
office building. The equipment pad is a remnant of
a former sanitary sewage pump house. Further to
the west of these areas, the Site is largely unused
and is overgrown with trees. Remnants of former
concrete aprons are visible, as are a former
refueling area used by the Navy. Currently, this
area Is overgrown and covered with piles of soil
and miscellaneous debris. To the south and west
of these aprons are the former barracks, swimming
pool, locker room, and the abandoned railroad spur
that formerly served the Site.
To the south of the hangar, the Site is largely
unused by TCOM and consists of open grassland,
forest, and swamp, which have overgrown features
formerly used by Triangle Pacific Corporation and
the Navy. This includes a former blimp tethering
area, as well as a closed landfill. This landfill was
reportedly used by Westinghouse and Triangle
Pacific Corporation from 1972 -1979, for the
disposal of wastes generated during the production
of wood cabinets. A map obtained from the Navy in
1990, as well as the U.S. Geological Survey
(USGS) topographic map for the Site, labels the
landfill area as "sewage disposal." Historically, the
landfill was mowed, but mowing has not been
continued in recent years, and the area is
overgrown with trees, shrubs, and bunch grass.
Northwest of the landfill is an area that contains the
former waste water treatment plant (WWTP) and
incinerator used by the Navy. These structures are
overgrown and in disrepair. To the west of these
3
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structures are two earthen pits of uncertain usage,
but presumably associated with the former VWVTP.
The area surrounding these pits contains a variety
of metal and concrete debris, and is the area from
which the remnants from approximately 30 to 40
steel drums and surrounding soil were removed as
part of the field investigation activities in 2011.
During the Rl, the above mentioned areas were
divided into several broad areas based on use to
facilitate the EPA's response actions in addressing
the cleanup of various media contaminated by the
former naval facility and wood cabinet treating and
preserving operations. These areas include the
storage tank area, wooded Area northwest of the
landfill, VWVTP and incinerator, on-site landfill, coal
storage area, Field North or wooded area, Former
Fuel Island Area, Areas surrounding the Blimp
Hangar, and Pailin Creek (Figure 2). As shown in
Table 3, for the anticipated industrial land use,
there were no unacceptable Human Health risks in
any of these areas mentioned above. There were a
few areas of unacceptable risk to ecological
receptors in areas near Palin Creek, and for future
risks from the groundwater near the center of the
site [Fig.4],
Regulatory History:
Several investigations have been performed at the
Site, beginning with the first phase of assessment
performed in 1987, and culminating with the
investigations conducted as part of the Rl in 2011
and 2012. These investigations have been
performed under the direct supervision or oversight
of EPA and the NCDEQ (or its precursor agency,
North Carolina Department of Environment, Health,
and Natural Resources [NCDENR]). Each
investigation was developed using information
obtained from prior investigations and has been
targeted to areas of the Site considered of most
concern. The following provides a brief overview of
these investigations:
• Nov 1987 Preliminary Assessment - The
NCDENR, Division of Health Services
performed the preliminary assessment,
assigned the Site a medium priority for
assessment, and determined that a site
inspection was needed to assess if the Site
posed a threat to human health and the
environment.
• Jun 1990 Phase I Screening Site
Investigation - The Phase I Screening Site
Investigation (SSI) was performed by
Greenhorne & O'Mara, Inc., under the direction
of the NCDENR. The SSI identified two
hazardous waste streams from manufacturing
operations (i.e., spent non-halogenated
solvent-based toner and lacquer thinner, and
lacquer dust). The investigation also identified
the presence of the on-Site landfill (Landfill
Area). The Phase I SSI also identified that the
Site was located near wetlands, as well as the
Pasquotank River and Newbegun Creek, and
that groundwater in the region was used as a
drinking water source. Based on the potential
for surface water and groundwater impacts, in
addition to potential worker exposure, the Site
was identified as representing potential risk to
human health and the environment and was
recommended for a high priority.
• Dec 1990 Phase II Screening Site
Investigation - This investigation was also
performed by Greenhorne & O'Mara, Inc.,
under the direction of the NCDENR and
included a site inspection, interviews, and
environmental sampling. The site inspection
and interviews provided more detail on
operations at the Site and identified the
presence of the Storage Tank Area and Boiler
House. Samples were collected from various
media to assess the potential for environmental
releases. These samples included two surface
soil, two surface water, three sediment, and
three groundwater samples. These samples
were analyzed for target compound list (TCL)
VOCs and semi-volatile organic compounds
(SVOCs), and target analyte list (TAL) metals
and cyanide. The analytical results for these
samples indicated the presence of various
constituents in environmental media. Based on
these results, an Expanded Site Investigation
(ESI) was recommended.
• 1992 Drum Removal - Contractors for the U.S.
Army Corps of Engineers (USACE) reportedly
removed 33 drums of material that were staged
at the Landfill. Information concerning the
contents of these drums has not been made
available by the USACE, and no information
was found in NCDENR files.
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• Dec 1995 Supplemental Screening
Inspection - This investigation was performed
by the EPA, at the request of the NCDENR Site
Management Branch, Waste Management
Division, and included the collection of four
surface soil and sediment samples. These
samples were analyzed for TCL VOCs, SVOCs,
pesticides, polychlorinated biphenyls (PCBs),
TAL metals and cyanide. No conclusions or
recommendations are provided in this report.
• Sep 1998 Expanded Site Investigation -
Based on the findings of the previous
investigations, and under the terms of an
Administrative Order on Consent (AO) entered
with the EPA, the Respondents conducted an
ESI to develop the data needed to rank the
Site, using the Hazard Ranking System (HRS),
for possible inclusion on the NPL. Under the
terms of that AOC, S&ME, Inc. performed the
ESI on behalf of the Respondents in 1997 and
1998. In scoping the ESI, sample locations
were selected, with input from the EPA and
NCDENR, from Site areas identified in prior
screening investigations to provide the data to
assess whether these areas were impacted.
Specifically, these included collection of soil
samples from a background location, the Tank
Storage Area Drum Storage Area, Boiler
House, Stacker Building, Tar Stained Soil Area,
and Landfill. Six monitoring wells were installed
and sampled including a background location.
Surface water and sediment samples were
collected from five locations on Pailin Creek.
Two sediment samples were also collected
from Newbegun Creek. These samples were
analyzed for TCL VOCs, SVOCs, pesticides,
PCBs, TAL metals and cyanide. Under an
agreement with EPA, NCDENR used the ESI
data to generate a HRS score for the Site.
Although EPA determined the site qualified for
listing on the NPL, EPA decided not to list the
site. Instead the site has been addressed as
"NPL equivalent".
4. SITE CHAR A C TERIS TICS
The Site is currently industrial use, but only a
portion of the 188 acres is actively used in
manufacturing operations. Much of the Site is open
land with low herbaceous vegetation or woodlands.
The adjacent waterfront property adjoining the
Pasquotank River (northeast, east, and southeast
of the Site) and Newbegun Creek (southeast and
east of the Site) is occupied by single-family
residential dwellings on large lots. This area of
residential development was also formerly a portion
of the Weeksville Naval Air Station. The nearest
residence in these areas is approximately 300 ft
from the Site, across Pailin Creek to the west.
Land uses to the west, northwest, and north of the
former Navy base are chiefly agricultural, including
row crops, although a former agricultural area along
the west bank of Pailin Creek has been developed
for residential properties. The US Coast Guard
airfield and the Elizabeth City Municipal Airport are
located approximately 3 miles northwest of the Site.
Pasquotank County has zoned most of the active
areas of the Site for industrial use with the southern
portion of the Site (which contains the Landfill and
is owned by the Respondents) zoned for residential
use. There is also a small area across Pailin Creek
which contains the former rail spur serving the Site
that is zoned residential. Projections of future land
use made by Pasquotank County are similar to the
zoning designations, except that the area on the
southern portion of the Site is projected to be used
for rural agriculture.
Site Topography:
The topography of the site is virtually flat with no
significant topographic relief. Site elevations range
between 6 and 12 feet (ft) above mean sea level
(amsl). The majority of the surface runoff from the
site is toward Pailin Creek.
Site Geology/Hydrogeology:
Two formations underlying the Site are of
significance for this investigation. These are the
Quaternary surficial deposits, and the underlying
Yorktown Formation. These two formations are
continuous throughout most of Pasquotank County.
The surficial deposits range from 30 ft thick in the
northern part to 60 ft thick in the southern part of
the County, but may be as much as 140 ft thick
along the Pasquotank River and parts of Albemarle
Sound. These deposits consist of interbedded
sands and clays deposited in marine and estuarine
environments, similar to those currently present in
the area.
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The surficial deposits unconformably overlie the
Yorktown Formation, which ranges in thickness
from 135 ft in northern Pasquotank County, to 185
ft in the southern part of the county. The type
section for the Yorktown Formation includes four
members, regionally including the bottom Member
consists of pebbly, coarse-grained sand overlying
shelly, fine-grained sand. This in turn is overlain by
a very fine-grained sandy clay with shell layers.
The uppermost Member consists of a sandy shell
hash and semi-indurated coquina. The Yorktown
pinches out to the west, and thickens to the east.
The Rl included investigation of the surficial
groundwater, which was encountered at depths
ranging from 3 to 11 feet below ground surface.
The groundwater beneath the Site is a current and
potential source of drinking water. The groundwater
is unconfined, and has a low gradient, with flow
across the Site generally to the west and south,
toward Pailin and Newbegun Creeks, although
potentiometric surfaces developed for the Rl
showed a complex and variable flow direction that
results in limited flow overall. Water levels in Pailin
and Newbegun Creeks are influenced by tides, and
fluctuate significantly. The northern portion of the
Site has many paved areas where infiltration is
limited. Precipitation in these areas will tend to run
off the paved surfaces and into storm sewers that
will rapidly carry the water to Pailin and Newbegun
Creeks.
5. NATURE AND EXTENT OF
CONTAMINATION
The following is a summary of the Site-related
contamination based on multiple Site investigations
conducted to date.
Surface Soil Contamination:
Several metals (arsenic, barium, cadmium, copper,
lead, selenium, vanadium and zinc) were detected
at concentrations exceeding ecological screening
levels at locations across the Site. Both cadmium
and arsenic were identified as constituents in the
lacquers formerly handled at the Site. Organic
chemicals that exceeded ecological screening
levels included total PCBs, high molecular weight
polycyclic aromatic hydrocarbons (HMWPAHs),
and 4,4"-dichlorodiphenyltrichloroethane (4,4'-
DDT). The highest concentrations of metals and
the organic chemicals were basically from two
locations (BH-18 and BH-26) in the former VWVTP
Area.
PCBs - PCBs are a class of manufactured, non-
naturally occurring chemicals that were used most
commonly in dielectrics, heat transfer, and
hydraulic fluids where there was a significant risk of
combustion. Production of PCBs was discontinued
in the U.S. in 1977. In 1978, uses of PCBs were
strictly limited under the Toxic Substances Control
Act (TSCA). PCBs were not a component of
previous cabinet manufacturing activities at the
Site. PCB Aroclors 1248,1254, and 1260 were
detected in surface soil at concentrations above
human health and ecological screening levels at
various locations across the Site (Figure 3).
"Aroclor" was a trademark for a commercial blend
of various PCB congeners, and different Aroclors
were designed for specific viscosities and other
properties. Aroclors 1254 and 1260 were most
commonly associated with dielectric fluids for
electrical transformers. Aroclor 1248 was more
commonly associated with heat transfer and
hydraulic fluids. The highest concentration of PCBs
(110 mg/kg) was in the former VWVTP Area (BH-
18).
High molecular weight PAHs - These constituents
are natural components of coal, oil, and tar, and
can also be produced by the partial combustion of
organic materials, coal, or oil. Potential sources of
PAHs at the Site include asphalt roads, roofing tar,
coal, motor oils and fuels, and other petroleum-
containing products. These HMWPAHs at the Site
exceeded ecological screening levels with the
highest concentration (765 mg/kg) in the former
VWVTP Area at BH-26.
4,4'-DDT- This pesticide was in widespread
agricultural and general use prior to being banned
in 1972. It was found at concentrations exceeding
ecological screening levels at several locations
across the Site. It was not a component of
previous cabinet manufacturing activities at the
Site. Its presence is likely attributable to aerial
spraying of the surrounding agricultural fields,
potentially for mosquito control, or possibly
localized historical spraying at the Site for pest
control. The highest concentrations of 4,4'-DDT
[5.5 mg/kg max] were in the former VWVTP Area at
locations BH-18 and BH-26.
6
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Groundwater Contamination:
Groundwater beneath the Site is classified as
current and potential sources of drinking water
(EPA Class II Aquifer)2. In North Carolina all
groundwater classifications of aquifers are potential
sources of drinking water and are expected to be
remediated for beneficial reuse (Class GA or Class
GSA under 15A NCAC 02L.0201).
VOCs - A combination of data collected from field
screening and laboratory analysis of groundwater
samples collected from monitoring wells has
identified the presence of a diffuse and extensive
trichloroethene (TCE) plume in groundwater
beneath the central area of the Site. The levels
range from below detection up to 290 ug/L. The
contaminant mass is largely within a cleaner,
coarser, and likely more transmissive sand present
at a depth of approximately 15 to 25 feet below
ground surface. The observed distribution of the
chlorinated VOCs, with most of the detections and
highest concentrations below 15 feet below ground
surface and virtually no detections above this
depth, suggest these TCE releases occurred
historically, are derived from widespread, low-
concentration releases to the ground surface, and
do not have a continuing source. Much of the area
of impact is unpaved; the shallow groundwater will
receive direct recharge from rainfall in this area.
TCE is somewhat soluble in water and is likely to
be leached rapidly from the soil into groundwater
with the percolation of rainwater. Over time, in the
absence of continued release, or with high residual
concentrations in soil, these constituents tend to be
leached from the soil, and carried deeper within
groundwater, ultimately being covered with a layer
of unimpacted water as these compounds are
removed entirely from the soil. Simultaneously, the
TCE would likely be moving downgradient,
particularly in the transmissive sand zone observed
from 15 to 25 feet below ground surface.
A supplemental groundwater investigation was
performed in September-October 2017. No
downgradient migration of TCE was observed,
although TCE concentration trends varied across
the plume. The objectives for this supplemental
investigation were to document trends in the
2 Guidelines for Ground-Water Classification Under the
EPA Ground-Water Protection Strategy, June 1988
concentration of TCE and its daughter products,
obtain geochemical data to characterize the
potential for natural attenuation, and measure
hydraulic conductivity. At present there is not
sufficient data to fully characterize plume stability,
characterize potential for migration, or determine if
the plume is undergoing natural attenuation. Other
VOCs detected in groundwater above NC 2L
standards include: 1,2-dichlorobenzene, 1,4-
dichlorobenzene, and vinyl chloride.
Metals - Groundwater samples collected from
monitoring wells has identified the presence of
metals in groundwater at the Site. Concentrations
of arsenic, cobalt, iron, manganese, and vanadium
were detected in groundwater above NC 2L
standards or IMACs [Arsenic max level was 286
mg/L], These include wells in the central area of
the site in the vicinity of the TCE plume, and wells
in the landfill area. In particular, the concentrations
of arsenic grossly exceeded groundwater standards
in monitoring wells near the landfill. At present
there is not sufficient data to fully characterize the
arsenic in groundwater or characterize the potential
for migration.
Pesticides - Groundwater samples collected from
one monitoring well (MW02) north of the TCE
plume, had concentrations of chlordane [2.4 ug/L]
and dieldrin [0.011 ug/L] above NC 2L standards.
PRINCIPLE THREAT WASTE
Principal threat wastes (PTWs) are highly toxic or
highly mobile materials that may present a
significant risk to human health or the environment
if exposure were to occur. They include liquids and
other materials having high concentrations of toxic
compounds (for example, solvents). Consistent with
the NCP and EPA guidance, the identification of
principal threats is made on a site-specific basis.
There were no site human health risks for the
anticipated industrial land use exceeding 1E-3
cancer risk, as a result, PTWwas not observed at
the Site.
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WHAT IS A "PRINCIPAL THREAT"?
The NCP establishes an expectation that EPA will
use treatment to address the principal threats posed
by a site wherever practicable (NCP Section
300.430(a)(1)(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 ground
water, surface water or air, or acts as a source for
direct exposure. Contaminated ground water
generally is not considered to be a source material;
however, Non-Aqueous Phase Liquids (NAPLs) in
ground water may be viewed as source material.
Principal threat wastes are those source materials
considered to be highly toxic or highly mobile that
generally cannot be reliably contained, or would
present a significant risk to human health or the
environment should exposure occur. The decision to
treat these wastes is made on a site-specific basis
through a detailed analysis of the alternatives using
the nine remedy selection criteria This analysis
provides a basis for making a statutory finding that
the remedy employs treatment as a principal
element.
6. SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) is required as
part of the Rl and provides an evaluation of the
potential threat to human health and the
environment in the absence of any remedial action.
The BRA provides the basis for determining
whether or not a remedial action is necessary and
the justification for performing a cleanup.
Consistent with EPA guidance and policy, the BRA
consists of a Human Health Risk Assessment
(HHRA) and an Ecological Risk Assessment (ERA).
The HHRA evaluated cancer and non-cancer risks
for existing Site conditions and current land and
water uses. The HHRA also includes an evaluation
of risk for reasonably anticipated future land use
scenarios.
The ERA included a quantitative evaluation of Site
risks to aquatic and terrestrial receptors for current
and future use scenarios.
Together, the HHRA and ERA are used to identify
an initial list of chemicals of potential concern
(COPCs) followed by a shorter list of chemicals of
concern (COCs), or those chemicals that exceed
risk-based concentrations and must be addressed
during development of remedial alternatives.
Tables 1 and 2 present a summary of COCs in Site
media (surface soil and groundwater). Table 1
shows the HHRA screening values. The ERA
screening values will be part of the final remedial
action decision. Table 2 shows the GW COCs with
MCLs/NC 2Ls shown. Table 3 shows the maximum
GW results.
Table 1. Chemicals of Concern in Soil
Metals
NC PSRG
EPA
mg/kg
mg/kg
Arsenic
3
3
Barium
44,000
22,000
Cadmium
200
98
Copper
9,400
4,700
Manganese
5,200
2,600
Lead
800
800
Vanadium
1,200
580
Zinc
70,000
35,000
SVOCs
Benzo(a)anthracene
2.9
2.9
Benzo(a)pyrene
0.29
0.29
Benzo(b)fluoranthene
2.9
2.9
Benzo(k)fluoranthene
—
—
Chrysene
290
290
Dibenz(a,h)anthracene
0.29
0.29
lndeno(1,2,3-cd)pyrene
2.9
2.9
PCBs
Aroclor-1254
—
1
Aroclor-1260
—
1
Pesticides
I 4,4-DDT
8.6
8.6
Table 1 Notes: mg/kg - microgram per kilogram; NC PSRG - North
Carolina Preliminary Soil Remediation Goal, Industrial Soil; USEPA
Region III Risk Based Screening Levels for Industrial Soil; SVOCs -
Semi Volatile Organic Compounds; - Screening value not available
Table 2. Chemicals of Concern in Groundwater
8
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Metals
mq/l
Source
Arsenic
10
NC 2L
Cobalt
1
NC IMACs
Iron
300
NC 2L
Vanadium
0.3
NC IMACs
VOCs
Mg/L
Source
1,2-Dichlorobenzene
20
NC 2L
1,4-Dichlorobenzene
6
NC 2L
Trichloroethene
3
NC 2L
Vinyl Chloride
0.03
NC 2L
Pesticides
Mg/L
Source
Total Chlordane
0.1
NC 2L
Dieldrin
0.002
NC 2L
Compounds.
Table 2 Notes: pg/L - microgram per liter; NC 2L - North Carolina
groundwater standards identified in 15A NCAC 2L, Last Amended on
April 1, 2013; NC IMACs - North Carolina Interim Maximum Allowable
Concentrations, Last Amended on April 6, 2018; VOCs - Volatile
Organic Compounds.
Table 3. Maximum Results for Chemicals of
Concern in Groundwater
Well,
Metals
Date
Max |jg/L
MW11,
Arsenic
2/1/12
286
MW11,
Cobalt
2/1/12
18.7
MW11,
Iron
2/1/12
96,600
MW01,
10/29/
Vanadium
12
3.3
VOCs
Well,
Date
Max ijg/L
1,2-
Dichlorobenzen
MW03
D,
10/30/
12
170
e
1,4-
Dichlorobenzen
e
MW03
D,
10/30/
12
12
MW03
Trichloroethene
D,
1/18
290
MW15
Vinyl Chloride
D,
10/30/
12
1 J
Pesticides
Well,
Date
Max pg/L
Total Chlordane
MW02,
2/2/12
2.4
Dieldrin
MW02,
2/2/12
0.11 J
Table X Notes: pg/L - microgram per liter; VOCs - Volatile Organic
HUMAN HEALTH RISK ASSESSMENT
Consistent with EPA guidance, the risk assessment
process included (1) data review and evaluation; (2)
exposure assessment; (3) toxicity assessment; (4)
risk characterization; and (5) uncertainty analysis.
See text box entitled, "What Is Risk and How Is It
Calculated" for details on each step.
The HHRA evaluated the carcinogenic risks and
non-carcinogenic hazards posed to on-site and
off-site human receptors from potential exposure to
site-related constituents in soil, sediment surface
water and groundwater under current and
reasonably anticipated future land use conditions.
Risks from consuming fish and blue crab exposed to
contaminated surface water or sediments in Pailin
Creek were also evaluated.
Receptor evaluations were segregated by exposure
units (EU) based on the site history, current and
probable future use, and known or suspected
human populations at and in the vicinity of the Site.
The Exposure Units consist of:
1. EU-1 - Active Facility Area: includes the
Storage Tank Area, Boiler House/Coal Storage
Area, and Stacker Building Area
2. EU-2 - Sitewide: includes both active and
inactive portions of the Site under investigation;
inactive portions include the Wastewater
Treatment Plant Area and the Closed Landfill
Area
3. EU-3 - Pailin Creek: includes the portion of
Pailin Creek bordering the Site
The following exposure pathways were considered
potentially complete for human receptors at the Site:
• Industrial workers - These workers are
associated with the manufacture and testing of
aerostats in the active portion of the facility
(EU-1).
• Utility/sewer line workers - These workers may
be exposed to constituents during installation or
repair of underground utilities or sewer lines in
the active portion of the facility (EU-1).
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• Construction workers - These workers may be
exposed to constituents during future
construction and/or excavation activities in the
active portion of the facility (EU-1),
• Trespassers - Adult trespassers (>18 years
old) and adolescent trespassers (12 to <18
years old) may access all portions of the Site
(EU-2).
• Recreational swimmers - These receptors may
be adults (>18 years old) or children (6 to <18
years old) that may access Pailin Creek (EU-3)
to wade or swim.
• Recreational fish anglers - These receptors
may be adults (>18 years old) or children (6 to
<18 years old) that may access Pailin Creek
(EU-3) to catch and consume sport fish.
• Recreational crab anglers - These receptors
may be adults (>18 years old) or children (6 to
<18 years old) that may access Pailin Creek
(EU-3) to catch and consume blue crabs.
• Child fish consumers - Young children (< 6
years old) may consume fish caught in EU-3 by
recreational anglers.
• Child crab consumers - Young children (< 6
years old) may consume blue crab caught in
EU-3 by recreational anglers.
On-site receptors are potentially exposed to
COPCs in soil and groundwater, and included
current and future industrial workers, current and
future utility workers, current and future
trespassers, and future construction workers.
Off-site receptors are potentially exposed to
COPCs in sediment, surface water, or food items in
the portion of Pailin Creek bordering the Site, and
included current and future recreational swimmers,
current and future child consumers of fish and blue
crab, and current and future recreational anglers.
CONCLUSIONS OF THE HHRA
Cancer risks and non-cancer hazards were
estimated for receptors under reasonable maximum
exposure (RME) and central tendency exposure
(CTE) scenarios. Remedial decisions are based on
the RME, consistent with the NCP.
The following conclusions were made based on the
results of the risk characterization:
• No unacceptable excess cancer risks3 are
estimated for on-Site or off-Site human
receptors from exposure to COPCs in media
potentially impacted by the Site under both
RME and CTE scenarios.
• No unacceptable non-cancer hazards4 are
estimated for on-Site or off-Site human
receptors from exposure to COPCs in media
potentially impacted by the Site under both
RME and CTE scenarios.
• Ingestion of drinking water from the aquifer
would present an unacceptable exposure.
At the request of EPA and NCDENR, a risk
evaluation based on hypothetical future residents
occupying the Site was conducted. Although
residential land use is not considered a reasonably
anticipated future use, the HHRA included a
residential evaluation to provide a baseline,
"worst-case" exposure scenario.
The following conclusions were made based on the
results of the hypothetical residential evaluation:
• Potentially unacceptable RME and CTE excess
cancer risks were estimated for both child and
adult residents, primarily associated with
exposure to benzo(a)pyrene in surface soil and
arsenic in shallow groundwater.
• Potentially unacceptable residential child and
adult RME and CTE non-cancer hazards are
presented by exposure to PCBs, metals.
SVOCs, and pesticides in surface soil and,
TCE, VOCs, metals, and pesticides in shallow
groundwater [see Tablel and 2],
The results of the HHRA indicate that future
hypothetical residential exposure to soil are
unacceptable. A complete discussion of all risks
from the Site can be found in the HHRA which is
contained in the Administrative Record.
3 Current Superfund regulations for exposures identify
the range for determining whether remedial action is
necessary as an individual excess lifetime cancer risk of
10-4 to 10-6, corresponding to a one-in-ten-thousand to
a one-in-a-million excess cancer risk.
4 For non-cancer health effects, a "hazard index" (HI) is
calculated. The key concept for a non-cancer HI is
exposures less than a specific "reference dose"
(measured as an HI of less than or equal to 1) are not
expected to result in adverse health effects.
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ECOLOGICAL RISK ASSESSMENT
The baseline ERA evaluated the potential for
adverse effects to ecological receptors from
exposure to contaminants on or associated with the
Site. The following receptor groups and exposure
pathways were evaluated in the baseline ERA:
• Benthic Invertebrates, Amphibians and
Aquatic Plants. Direct contact with sediment,
surface water, and pore water. Risk to these
receptors was evaluated through comparison of
sediment, surface water and pore water
contaminant concentrations with sediment and
surface water screening benchmarks.
• Fish. Direct contact with surface water, and
ingestion of prey items. Risk to fish was
evaluated by comparing surface water
contaminant concentrations to surface water
screening benchmarks and comparing
measured fish tissue contaminant
concentrations with fish tissue screening
benchmarks
• Aquatic-Associated Birds and Mammals.
Contact with sediment and ingestion of prey
items. Risk to aquatic associated birds and
mammals (e.g. heron and otter) was evaluated
by modeling the contaminant doses from
ingesting prey items and incidental sediment
ingestion from Pailin Creek, and comparing
these doses to toxicity reference values.
• Terrestrial Birds and Mammals. Ingestion of
soil biota and incidental ingestion of soil. Risk
to terrestrial birds and mammals was evaluated
by modeling the contaminant doses from
ingesting prey items and incidental soil
ingestion from the site, and comparing these
doses to toxicity reference values.
CONCLUSIONS OF THE ERA
The baseline ERA evaluated risks to receptors
under current use scenarios. A BERA quantifies
risk to different potentially exposed ecological
receptors as a Hazard Quotient (HQ). If an HQ is
calculated to be equal to or less than 1, then no
adverse effects are expected as a result of
exposure. If the HQ is greater than 1, adverse
effects are possible.
Unacceptable ecological risk to aquatic organisms,
birds and mammals associated with exposure to
surface water, sediment or biota of Palin Creek is
unlikely. However, residual concentrations of
COCs (PCBs, PAHs, metals) in soil at localized
areas on the Site potentially pose unacceptable
risks to terrestrial wildlife (songbirds and small
mammals),
BASIS FOR ACTION
Based on the results of the Rl and the risk
assessments, EPA has determined that the
Preferred Alternative, or one of the other remedial
alternatives presented in this Interim Action
Proposed Plan, is necessary to protect public
health or welfare and the environment from
hazardous substances released at the Site.
Figure 3 and Figure 4. respectively illustrate the
location and extent of the surface soil for ecological
risks and groundwater contamination for human
health ingestion risks to be addressed by this
interim remedial action.
Surface Soil: The aggregate ecological risk to the
upper trophic level receptors is driven by the
concentration of PCBs, HMWPAHs, 4,4'-DDT and
several metals notably arsenic, cadmium, copper,
lead, selenium and zinc in the surface soil at two
locations. The area at each location is estimated to
be approximately 20 by 20 feet, with a depth of 1
foot. The total estimated volume of impacted soil
for both locations is estimated to be 800 cubic feet.
Groundwater: The area exhibiting concentrations
of TCE above the NC 2L Groundwater Level of 3
micrograms per liter (pg/L) was estimated
conservatively by using the total chlorinated
compound contours from the Rl. The estimated
area is approximately 462,500 square feet with and
average thickness of 20 ft (see Figure 4).
Additionally, concentrations of arsenic, cobalt, iron,
vanadium, 1,2-dichlorobenzene, 1,4-
dichlorobenzene, vinyl chloride, Total Chlordane,
and dieldrin were found above the NC 2L
Groundwater Levels or NC IMACs [NC Interim
Maximum Allowable Concentrations], and are for
the most part located within the footprint of the TCE
plume, except for metals which are also located in
the area of the landfill. This interim action is
designed to address organic contaminants only.
CHEMICALS OF CONCERN
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The COCs determined from the results of the BRA
were identified based on EPA's guidance. COCs
are chemicals that significantly contribute to an
exposure pathway that either exceeds a 1 x 104
cumulative site cancer risk or exceeds a non-
cancer hazard index (HI) of 1. The COCs and
preliminary remedial goals (PRGs) identified in the
HHRA for groundwater at the Site are listed in
Table 3. Soil ecological PRGs have yet to be
determined; they will be completed as part of the
pre-removal investigation, as the cleanup numbers
will change based on the assessment of aggregate
risk.
7. REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) describe in
general terms what a remedial action should
accomplish to be protective of human health and
the environment. RAOs are statements that specify
the environmental media of concern, contaminant
type, potential exposure pathways to be addressed
by remedial actions, receptors to be protected, and
remediation goals or cleanup levels (40 CFR
Section 300.430[e][2][i]). The RAOs section of the
Proposed Plan should clearly present the intended
results of the remedial action (EPA, 1999b). The
RAOs for the interim remedial action are
summarized below.
The site-specific interim RAOs are as follows:
Surface Soil:
• Minimize ecological exposure (i.e., direct
exposure and incidental ingestion) to COCs in
soil that pose unacceptable ecological risk.
Groundwater:
• Minimize off-site migration of COCs in
groundwater to off-site surface water or
potential groundwater Points of Exposure
(POEs) at concentrations exceeding the
Federal Safe Drinking Water Act (SWDA)
Maximum Contaminant Levels (MCLs) and
NCDEQ drinking water quality standards (15A
NCAC 02L.0201).
• Restore TCE levels in groundwater [Table 4] to
the extent practicable to meet Federal SWDA
MCLs and NCDEQ drinking water quality
standards throughout most of the plume, based
on the classification of the aquifers as a
potential source of drinking water (Class GA or
Class GSA) under 15A NCAC 02L.0201.
Remaining residuals of TCE and other
contaminants that exceed MCLs or 2L levels will be
addressed in the final remedy for the Site.
8. PRELIMINARY REMEDIA TION GOALS
In general, preliminary remediation goals (PRGs)
are used to develop the long-term contaminant
concentrations needed to be achieved to meet
RAOs by the remedial alternatives. These goals
must comply with Applicable or Relevant and
Appropriate Requirements (ARARs) (or the basis
for a waiver must be provided) and result in
residual risk levels that fully satisfy the CERCLA
requirements for the protection of human health
and the environment. PRGs are based on ARARs,
risk-based concentrations if standards are not
available or not sufficiently protective, or
background concentrations of contamination.
PRGs may be further modified through the
evaluation of alternatives and the remedy selection
process.
PRGs for the interim groundwater response action
are presented in the Table 5 below.
Table 4. Preliminary Remediation Goals for
Chemicals of Concern in Groundwater
VOCs
Mg/L
Source
Trichloroethylene
3
NC 2L
PRGs for the final groundwater response action will
be determined based on additional Site
characterization. Groundwater cleanup levels will
be documented in the final ROD for the Site.
PRGs for the interim ecological soil response action
have not been developed. The horizontal and
lateral extents of the soil contamination illustrated
on Figure 3 are based on the aggregate ecological
risk to upper trophic level receptors is driven by the
concentration of metals, 4,4-DDT, PCBs, and high
molecular weight PAHs in surface soil at two
isolated locations. Ecological-risk based soil
cleanup levels will be documented in the final ROD
for the Site.
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WHAT IS RISK AND HOW IS IT CALCULATED?
Human Health Risk
A Superfund human health risk assessment estimated the "baseline risk." This is an estimate of the likelihood of
health problems occurring if no cleanup action were taken at a site. To estimate the baseline risk at a Superfund site,
EPA undertakes a four-step process:
In Step 1, EPA looks at the concentrations of contaminants found at a site as well as past scientific studies on the
effects these contaminants have had on people (or animals, when human studies are unavailable). Comparisons
between site-specific concentrations and concentrations reported in past studies help EPA to determine which
contaminants are most likely to pose the greatest threat to human health.
In Step 2, EPA considers the different ways that people might be exposed to the contaminants identified in Step 1, the
concentrations that people might be exposed to, and the potential frequency and duration of the exposure. Using the
information, EPA calculates a "reasonable maximum exposure" (RME) scenario, which portrays the highest level of
human exposure that could reasonably be expected to occur.
In Step 3, EPA uses the information from Step 2 combined with information on the toxicity of each chemical to assess
potential health risks. EPA considers two types of risk: cancer risk and non-cancer risk. The likelihood of any kind of
cancer resulting from a Superfund site is generally expressed as an upper bound of probability; for example a "1 in
10,000" chance." In other words, for every 10,000 people that could be exposed, one extra cancer may occur as a
result of exposure to site contaminants. EPA's target range for acceptable cancer risk is "1 in 1,000,000" to "1 in
10,000." These probabilities are often expressed in scientific notation (i.e., 1 x 10-® or 1E -6 to 1 x 10~4 or 1E -4). An
extra cancer case means that one more person could get cancer than would normally be expected to from all other
causes. For non-cancer health effects, EPA calculates a "hazard index." The key concept here is that a "threshold
level" (measured usually as a hazard index less than 1) exists below which non-cancer health effects are no longer
predicted.
In Step 4, EPA determines whether site risks are great enough to cause health problems for people at or near the
Superfund site. The results of the three previous steps are combined, evaluated, and summarized.
Ecological Risk
Current EPA guidance recommends an eight-step process for designing and conducting ecological risk assessments
(ERAs) for the Superfund Program. Steps 1 and 2 constitute a screening level ecological risk assessment (SLERA),
which compares existing site data to conservative screening level values to identify those chemicals which can
confidently be eliminated from further evaluation, and those for which additional evaluation is warranted. At the end of
Step 2, all involved parties meet and discuss whether: there is adequate information to conclude that ecological risks
are negligible and therefore no need for remediation on the basis of ecological risk; if the information is not adequate
to make a decision at this point, the ERA process will continue to Step 3; or the information indicates a potential for
adverse ecological effects, and a more thorough assessment is warranted.
If further evaluation is warranted, Step 3 of the eight-step process is initiated as the planning and scoping phase for
implementing a baseline ecological risk assessment (BERA), Step 3 includes several activities, including refinement
of the list of contaminants of potential concern (COPCs), further characterization of ecological effects, refinement of
information regarding contaminant fate and transport, complete exposure pathways, ecosystems potentially at risk,
selecting assessment endpoints, and developing a conceptual model with working hypotheses or questions that the
site investigation will address. In Step 4, a sampling and analysis plan (SAP) is developed and used to gather further
data to support the BERA. Step 5 is a site visit to verify the Step 4 sampling design. Step 6 of the process is the
actual data collection for the BERA. Step 7 is the summary and analysis of the data, and prediction of the likelihood of
adverse effects based on the data analysis, which is presented as the risk characterization. It also includes
consideration of uncertainties and ecological significance of risks in view of the types and magnitude of effects, spatial
and temporal patterns, and likelihood of recovery. Step 8, the final step, results in a discussion of significant risks,
recommended cleanup (if any), and future efforts.
Step 1: Analyze Contamination
Step 3: Assess Potential Health Dangers
Step 2: Estimate Exposure
Step 4: Characterize Site Risk
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9, SUMMARY OF REMEDIAL ALTERNATIVES
Consistent with CERCLA, interim actions should be
protective of human health and the environment in
the short term, and is intended to provide adequate
protection until a final ROD is implemented;
complies with (or waives) those federal and state
requirements that are applicable or relevant and
appropriate for the limited-scope action; and be
cost-effective. Interim actions may employ
permanent solutions and alternative treatment
technologies and resource recovery alternatives to
the maximum extent practicable. Interim actions will
need to be followed at some point in the future with
a final remedial action documented in a ROD.
Remedial alternatives for the interim soil and
groundwater response action are summarized
below. More detailed descriptions of the remedial
alternatives can be found in the FS report. Capital
costs are those expenditures that are required to
construct a remedial alternative. Operational and
Maintenance (O&M) costs are those post-
construction costs necessary to ensure or verify the
continued effectiveness of a remedial alternative
and are estimated on an annual basis. Present
worth is the amount of money which, if invested in
the current year, would be sufficient to cover all the
costs over time associated with a project,
calculated using a discount rate of seven percent
and a 30-year time interval. Construction time is the
time required to construct and implement the
alternative and does not include the time required
to design the remedy, negotiate performance of the
remedy with the responsible parties, or procure
contracts for design and construction.
Monitored Natural Attenuation was evaluated in the
FS; however, insufficient evidence was gathered
during the Rl to determine if MNA would be
effective at restoring groundwater to beneficial use
or as part of this interim remedial action. MNA will
be evaluated as a potential alternative for
groundwater in the final remedy for the Site.
Remedial Alternatives for the soil response action
included: No Action and Excavation and Off-Site
Disposal. Remedial Alternatives for the
groundwater response action include: No Action,
Institutional Controls (ICs), and Enhanced In-Situ
Bioremediation and ICs.
Because hazardous substance will be left behind at
levels that do not allow for unlimited use and
unrestricted exposure, five-year reviews will be
required for each alternative, as required by
CERCLA 121(c) and the NCP[40C.F.R.
§300.430(f)(4)(H)]
Surface Soil
Alternative 1: No Action
Estimated Capital Cost: $0
Estimated Annual O&M Costs: $0
Net Present Value: $0
Estimated Time to Achieve RAOs Not Applicable
The NCP requires that a "No Action" alternative be
developed as a baseline for comparing other
remedial alternatives. No active cleanup activities
will be initiated. This alternative provides for an
assessment of the environmental conditions if no
remedial actions are implemented
Alternative 2: Excavation and Off-Site Disposal
Estimated Capital Cost; $151.050
Estimated Annual O&M Costs: $0
Net Present Value: $151,050
Estimated Time to Achieve RAOs
Alternative 2 consists of 'hot spot' removal or
excavation of surface soil (up to 1 foot below
ground surface) at two locations, where
concentrations of COCs drive ecological risk for the
Site; off-site disposal at a Resource Conservation
Recovery Act (RCRA) Subtitle D (solid waste),
RCRA a Subtitle C (hazardous waste) or a TSCA.
Subtitle D landfill depending on the nature of the
waste. Confirmation samples will be collected and
the open excavation areas will be backfilled with
clean fill. ICs will be implemented by the state to
prohibit residential use and redevelopment of the
areas addressed by this interim action.
Groundwater
Alternative 1: No Action
Estimated Capital Cost; $0
Estimated Annual O&M Costs: $0
Net Present Value: $0
Estimated Time to Achieve RAOs Not Applicable
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NINE CRITERIA FOR SUPERFUND REMEDIAL ALTERNATIVES
THRESHOLD CRITERIA
1 Overall Protectiveness of Human Health and the Environment determines whether an alternative eliminates, reduces, or
controls threats to public health and the environment through institutional controls, engineering controls, or treatment.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) evaluates whether the alternative meets
Federal and State environmental statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified.
PRIMARY BALANCING CRITERIA
3. Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the
environment over time.
4. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use of treatment to
reduce the harmful effects of principal contaminants, their ability to move in the environment, and the amount of contamination present,
5. Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to
workers, residents, and the environment during implementation.
6. Implementability considers the technical and administrative feasibility of implementing the alternative, including factors such as
the relative availability of goods and services.
7. Cost includes estimated capital and annual operations and maintenance costs, as well as present worth cost. Present worth cost
is the total cost of an alternative over time in terms of today's dollar value. Benefits weighed against cost,
MODIFYING CRITERIA
8. State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses and recommendations, as
described in the RI/FS and Proposed Plan,
9. Community Acceptance considers whether the local community agrees with EPA's analyses and preferred alternative.
Comments received on this Proposed Plan are an important indicator of community aeeeptanee.
The NCR requires that a "No Action" alternative be
developed as a baseline for comparing other
remedial alternatives. No active cleanup activities
will be initiated. Periodic monitoring of existing wells
and reporting will be completed every five years to
confirm Site conditions. This alternative provides for
an assessment of the environmental conditions if
no remedial actions are implemented.
Alternative 2: Institutional Controls
Estimated Capital Cost: 570,000
Estimated Annual O&M Costs: $0
Net Present Value: $70,00
Estimated Time to Achieve RAOs
ICs in the form of deed restrictions would be
established for the Site. These ICs would prevent
exposure (for example, dermal contact, ingestion
and inhalation) to COCs in groundwater. A
restriction to prohibit installation of a groundwater
production well at the Site or to prohibit the use of
the groundwater as a source for drinking water
without appropriate treatment would control
exposure to groundwater.
Alternative 3: Enhanced Bioremediation and
Institutional Controls
Estimated Capital Cost: $904,424
Estimated Annual O&M Costs: $297,674
Net Present Value: $1,202,099
Estimated Time to Achieve RAOs
Enhanced bioremediation involves the injection of a
liquid amendment (e g, 3D Microemulsion® or
similar) to enhance the biodegradation of
chlorinated compounds in the groundwater via
reductive dechlorination. Enhanced biodegradation
would be conducted in the area surrounding
monitoring well MW-03 with the objective of
accelerating the degradation of the organic COCs
(TCE) in groundwater to reduce the concentration
below levels that may represent a risk for potential
exposure due to ingestion of drinking water In
addition, enhanced biodegradation would create a
15
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biologically active area on the downgradient edge
of the TCE plume, further limiting the potential for
migration to off-site surface water and groundwater
POEs, thus facilitating groundwater restoration.
A treatability study may be conducted during the
Remedial Design phase to evaluate potential
enhancements that would be effective for treating
TCE at the Site. Enhanced biodegradation will not
be immediately effective; therefore, ICs will be
implemented as described in Alternative 2 until
RAOs are achieved.
10. EVALUATION OF ALTERNATIVES
This section of the Proposed Plan describes the
relative performance of each alternative against the
nine criteria (see table entitled, "Evaluation Criteria
for Superfund Remedial Alternatives") noting how
each compares to the other options under
consideration. A detailed analysis of the
alternatives can be found in the FS Report.
The nine criteria and a summary of the evaluation
are provided below. The first two criteria are
threshold criteria (Overall Protection of Human
Health and the Environment and Compliance with
ARAR), that alternatives must meet to be
considered.
The EPA will recommend the alternative that
provides the best balance of tradeoffs between the
five the Primary Balancing Criteria. The EPA, after
considering State (NCDEQ) acceptance and public
comments received on this proposed plan, will
select the interim remedy in the ROD.
OVERALL PROTECTIVENESS OF HUMAN
HEALTH AND THE ENVIRONMENT
The No Action Alternatives for soil and groundwater
would not be protective of human health and the
environment and therefore, are not carried forward.
Surface Soil
Alternative 2, Excavation and Off-Site Disposal is
protective of human health in the short term. Under
the current and reasonably anticipated future land
use (industrial), soil does not pose an unacceptable
risk to human health. There is unacceptable risk to
future residents from exposure to COCs in soil
should it be used in the future that could be
addressed through additional response actions or
ICs, prohibiting residential use.
Alternative 2 is protective of the environment in the
short-term because it removes soil containing the
highest COC concentrations. A follow-up ecological
risk assessment will be conducted at the Site, after
the interim soil response action is implemented to
determine if a CERCLA response is needed to
address residual contamination.
Groundwater
Alternatives 2 and 3 are protective of human health
and the environment in the short term. Under the
current and reasonably anticipated future land use
(industrial) there are no unacceptable risks
associated with exposure to groundwater because
it is not used at present as a drinking water source.
There is unacceptable risk to future residents from
exposure to COCs in groundwater should it be
used in the future and this would be addressed in
the interim through treatment and ICs.
A groundwater migration evaluation (2018 FS,
Appendix B) indicates that TCE is unlikely to impact
off-site groundwater and surface water points of
exposure, and therefore does not represent a
potential risk to human or ecological receptors in
off-site areas.
COMPLIANCE WITH ARARS AND TO-BE-
CONSIDEREDS (TBCS)
As defined by CERCLA Section 121, specified
remedial actions shall be protective of human
health and the environment. Applicable and
Relevant or Appropriate Requirements (ARARs)
and to-be-considered materials (TBC) have been
used to specify the level of protection of human
health and the environment.
Surface Soil
Alternative 2 would attain chemical-specific ARARs
by removing soils above protective levels for
ecological concerns. Excavation and backfilling
activities under Alternative 2 would be conducted in
a manner consistent with floodplain regulations and
air quality standards. Solid and TSCA wastes would
be managed in accordance with applicable state
and federal handling and disposal regulations.
Transportation activities would be completed in
accordance with applicable state and federal
requirements, by licensed and permitted haulers.
Groundwater
16
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Alternative 2, Institutional Controls would not attain
chemical-specific ARARs. Alternative 3, Enhanced
Bioremediation, would achieve chemical-specific
ARARs in the treatment zone over a more rapid
timeframe. Achievement of the State and Federal
drinking water standards would be achieved in a
future ROD.
Location-specific ARARs are not triggered by
Alternative 2. All Solid wastes associated with
Alternative 3 would be managed in accordance with
applicable state and federal handling and disposal
regulations. Transportation activities would be
completed in accordance with applicable state and
federal requirements, by licensed and permitted
haulers. Injection of bioremediation chemicals
would follow North Carolina for injection control.
LONG-TERM EFFECTIVENESS AND
PERMANENCE
Surface Soil
Alternative 2, Excavation and Off-Site Disposal,
provides some degree of long-term protection.
Alternative 2, removes the highest levels of soil
contamination from the Site.
No long-term pollutant emissions, impacts to water,
ecology, or community are anticipated for
Alternative 2.
Groundwater
Alternatives 2 and 3 provide some degree of long-
term protection. There are no long-term human or
community impacts associated with the
implementation of any of the three alternatives.
REDUCTION OF TOXICITY, MOBILITY, AND
VOLUME THROUGH TREATMENT
Surface Soil
Alternative 2 does not include treatment to reduce
toxicity, mobility, or volume of COCs in soil.
SHORT TERM EFFECTIVENESS
Surface Soil
Alternative 2 would negatively impact the
environment and community in the short term due
to increased construction traffic during excavation
activities. However, minimal pollutant emissions,
impacts to water, ecology, or community are
anticipated. Higher fuel use/greenhouse gas
emissions, associated with the operation of
construction equipment and off-site shipping, are
anticipated with Alternative 2. Physical hazards
relating to the movement of heavy equipment and
vehicles associated with remedial construction
activities would be anticipated. Chemical hazards
related to Site COCs in dust and surface runoff
would be anticipated and controlled appropriately
during excavation. Safety equipment and personal
protective equipment would protect workers from
exposure. Proper construction controls will be
implemented to minimize environmental and
community impact. Anticipated nuisance conditions
associated with Alternative 2 include dust and noise
generation, runoff, and additional traffic due to
construction equipment. Proper construction
controls would be implemented to provide
community protection.
Groundwater
There are no short-term human or community
impacts associated with the implementation of
Alternatives 2 or 3. Short-term impacts associated
with physical hazards to workers and the
community, as well as impacts from emissions,
would be addressed for Alternative 3 through
accepted health and safety and construction
practices. There would be some short-term
environmental and sustainability impacts
associated with the implementation Alternative 3.
Specifically, construction activities would generate
greenhouse gases (emissions from vehicles) and
consume fossil fuel. Green remediation techniques
would be considered to reduce the short-term
impacts of the remedy.
IMPLEMENTABILITY
Surface Soil
Alternative 2 is readily implemented. Potential for
additional on-site traffic due to construction
equipment could impact the day-to-day activities of
one of the current site owners, TCOM LP.
Groundwater
Alternatives 2 and 3 are readily implementable and
necessary specialists and materials are readily
available. No difficulties are anticipated related to
instituting ICs. The treatment technology in
Alternative 3 is readily constructive, and
equipment, materials, and specialists are readily
available, although a treatability study would be
required to verify effectiveness. Effectiveness of
17
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remediation included in Alternative 3 is easily
monitored. Because of disruption to on-going
business activities and nuisance to neighboring
residences, Alternative 3 is less easy to implement
than Alternative 2.
COST
Surface Soil - Budgetary cost estimates were
prepared for each alternative, based on vendor
information and quotations, cost estimating guides,
and experience. Budgetary cost estimates were
prepared for the purpose of alternatives
comparison, and were based on site-specific
information, when available. The budgetary cost
estimates include capital costs, annual O&M costs,
periodic O&M costs, and present worth cost. The
present worth cost for these alternatives was
calculated for the expected duration of the remedy
using the current Office of Management & Budget
(OMB) discount rate of 7%. The estimated costs
for surface soil remedial alternative are shown
below.
Groundwater - Cost estimates were prepared for
each alternative based on vendor information and
quotations, cost estimating guides, and experience.
Cost estimates were prepared for the purpose of
alternatives comparison and were based on site-
specific information, when available. The cost
estimates include capital costs, annual O&M costs,
periodic O&M costs, and present worth cost. The
present worth cost for these alternatives was
calculated for the expected duration of the remedy
using the OMB discount rate of 7%. The estimated
costs for groundwater remedial alternative are
shown below.
The estimated total cost of this preferred remedial
alternative is $1,353,149. This alternative consists
of removal and disposal of surface soil, along with
establishing ICs for the Site in the form of deed
restrictions to prevent instillation of groundwater
production wells on-site.
State Acceptance:
NCDEQ has been actively involved in the
development and review of the Rl, FS, and the
cleanup plan for the Site. The State supports the
preferred alternatives selected.
Community Acceptance:
Community acceptance of the preferred
alternatives will be evaluated subsequent to the
Proposed Plan comment period. Comments
received during the public comment period will be
addressed and responses will be presented in the
Responsiveness Summary, which will be included
in the Interim ROD.
Remedial Alternatives Cost Estimate Summary for Groundwater Alternatives
Alternatives
Total Estimated
Capital Present
Worth Cost
Total Estimated
Present Worth of
O&M (30 years)
Total
Estimated
Net Present
\ A f ,41,
Alternative 1: No Further Action
$0
$0
$0
Alternative 2: Institutional Controls
$ 70,000
$0
$ 70,000
Alternative 3: Groundwater Enhanced
Bioremediation and Institutional Controls
$904,424
$297,674
$1,202,099
Remedial Alternatives Cost Estimate Summary for Soil Alternatives
Alternatives
Total Estimated
Capital Present
Worth Cost
Total Estimated
Present Worth
of O&M
Total
Estimated Net
Present
Alternative 1: No Further Action
$0
$0
$0
Alternative 2: Excavation and Disposal
in a Commercial Facility
$151,050
$ 0
$151,050
18
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Preferred Alternative
Phase Action
Based on the information currently available, EPA
believes the Preferred Alternative for the interim
soil and groundwater response action meets the
threshold criteria and provides the best balance of
tradeoffs among the other alternatives with respect
to the balancing criteria.
EPA's Preferred Alternative is a combination of:
• Alternative 2, Excavation and Off-Site
Disposal
• Alternative 3, Groundwater Enhanced
Bioremediation and ICs
• The net present value of Alternative 2 and
Alternative 3 are $151,050.00 and
$1,202,099.00, respectively. The total net
value of the Preferred Alternative is
$1,353,149.00.
It is anticipated that interim soil and groundwater
response actions will be implemented in phases.
The recommended phasing is listed below. It is
expected that some of these phases can proceed
on simultaneous tracks.
Phase Action
unacceptable risk from ingestion of
groundwater. Enhanced Bioremediation
will also create a biologically active area
on the downgradient edge of the TCE
plume, further limiting the potential for
TCE migration to off-Site surface water
and groundwater POEs.
The interim soil response action will address soil
with the highest COC concentrations. A
supplemental risk assessment will be conducted at
the Site, after the interim soil response action is
implemented to determine if a CERCLA response is
needed to address residual contamination.
ICs will prevent unacceptable risk to human health
by preventing exposure to contaminated
groundwater. ICs include, but are not limited to, the
following:
1. The Triangle Pacific property would be for
industrial/ commercial uses only.
2. Restrictive covenants would prohibit potable
groundwater use on the facility and adjacent
impacted properties.
Permanent access to the property shall be granted
to EPA and NDEP and their agents and/or
representatives.
The Preferred Alternative is expected to be
protective of human health and the environment in
the short term and is intended to provide adequate
protection until a final remedy is implemented. The
Preferred Alternative is expected to comply with or
waive ARARs for the limited-scope action and be
cost effective.
This proposed action is not intended to utilize
permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum
extent practicable for this Site. Because this
proposed action does not constitute the final
remedy for the Site, the statutory preference for
remedies that employ treatment that reduces
toxicity, mobility, or volume as a principle element
will be addressed by the final response action.
Subsequent actions are planned to address fully
the threats posed by conditions at the Site.
Because the Preferred Alternative will result in
potentially hazardous substances remaining on-site
above health-based levels, a review will be
I
Establishment of Institutional Controls
II
Excavation of surficial soil to address
unacceptable risk from direct contact with
COCs. Excavated soil will be sampled to
determine if disposition at a RCRA C,
RCRA D or TSCA disposal facility is
required.
III
Supplemental Ecological Risk
Assessment. A follow-up ecological risk
assessment will be conducted at the Site,
after the interim soil response action is
implemented to determine if a CERCLA
response is needed to address residual
contamination. A follow-up decision
document will be issued to document the
decision after a Proposed Plan.
IV
Conduct the Enhanced Bioremediation
Treatability Study. Evaluate potential
enhancements that would be effective for
treating TCE at this Site.
V
Implementation of Enhanced
Bioremediation. Focusing on the area
surrounding MW-03 will accelerate the
degradation of TCE and address potential
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conducted to ensure that the remedy continues to
provide adequate protection to human health and
the environment within five years after
commencement of the remedial action.
A follow-up ecological risk assessment will be
conducted at the Site, after the interim soil
response action is implemented to determine if a
CERCLA response is needed to address residual
contamination.
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For further information on the Site, please contact:
DOCUMENT INFORM A TION
Jon Richards, Remedial Project Manager
404-562-8648
E-mail: Richards.Jon@epa.gov
or
Stephanie Yvette Brown, Community Involvement
Coordinator
(404) 562-8450 or (877) 718-3752 (toll free)
E-mail: brown.stephaniey@epa.gov
U.S. EPA Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
The Administrative Record contains all the
information used by the Agency to select a
Remedial Action.
Copies of the Administrative Record are kept at:
Pasquotank-Camden Library
100 East Colonial Ave.
Elizabeth City, NC 27909
Phone: (252 ) 335-2473
Hours: Mon, Wed, & Fri: 8:30 a.m. - 6:30 p.m.
Tue & Thu: 8:30 a.m. - 7:00 p.m.
Sat: 10:00 a.m. - 2:00 p.m.
U.S. Environmental Protection Agency Region 4 -
Records Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
Phone: (404) 562-8816
Hours: Monday - Friday 8 a .m. - 4 p.m.
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Administrative Record: Materials, information and documents
that provide the basis and support EPA's selection of a remedial
action at Superfund sites usually placed in the information
repository near the Site.
Applicable or Relevant and Appropriate Requirements
(ARARs): Refers to Federal and more stringent State
environmental requirements a selected remedy must attain which
vary from site to site. Reference 40 CFR 300.5 Definitions of
'Applicable requirements' and 'Relevant and appropriate
requirements'.
Aquifer: An underground geologic formation, or group of
formations, containing water.
Baseline Risk Assessment (BRA): A qualitative and quantitative
evaluation performed in an effort to define the risk posed to human
health and the environment by the presence or potential presence
and use of specific pollutants.
Chemical of Concern (COCs): Chemical constituents associated
with a Superfund Site that have been released into the
environment and pose an unacceptable risk to human health.
Cleanup: Actions taken to deal with a release or threat of release
of a hazardous substance that could affect humans and/or the
environment. The term "cleanup" is sometimes used
interchangeably with the terms remedial action, removal action,
response action, or corrective action.
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA): Also known as Superfund, is a federal
law passed in 1980 and modified in 1986 by the Superfund
Amendment and Reauthorization Act (SAF5A). The act created a
trust fund, to investigate and cleanup abandoned or uncontrolled
hazardous waste sites.
Ecological Risk Assessment (ERA): A qualitative and
quantitative evaluation performed in an effort to define the risk
posed to ecological receptors by the presence or potential
presence of specific contaminants.
Feasibility Study (FS): Study conducted after the Remedial
Investigation to determine what alternatives or technologies could
be applicable to the site specific COCs.
Groundwater: Water located beneath the ground surface in soil
pore spaces and in the fractures of lithologic formations.
Information Repository: A library or other location where
documents and data related to a Superfund project is placed to
allow public access to the material.
In situ: In its original place; unmoved unexcavated; remaining in
the subsurface.
Institutional Controls (ICs): Administrative, non-engineering,
controls that inform and prevent exposures to human receptors.
Monitored Natural Attenuation (MNA): This term refers to the
reliance on natural attenuation processes to achieve site-specific
remediation objectives. The natural attenuation processes that are
at work in such remediation approach include a variety of physical,
chemical, or biological processes that, under favorable conditions,
act without human intervention to reduce the mass, toxicity,
mobility, volume, or concentration of contaminants in soil or
groundwater.
Monitoring: The periodic or continuous surveillance or testing to
determine the level of pollutants in various media.
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP): The federal regulation that guides the
Superfund program.
National Priorities List (NPL): EPA's list of the most serious
uncontrolled hazardous waste sites identified for possible long-
term remedial response. This list is based primarily on the score a
site received on the Hazard Ranking System.
Proposed Plan: Document that summarizes the RI/FS, the
alternatives developed and the proposed preferred alternative and
the rationale for its proposal
Public Comment Period: The time allowed for the public to
express its views and concerns on the information provided in the
Proposed Plan and EPA's proposed preferred alternative.
Record of Decision (ROD): A decision document that selects and
describes the remedy that will be implemented at a Site. The ROD
is based on information and technical analysis generated during
the remedial investigation/feasibility study and consideration of
public comments.
Remedial Action (RA): The actual construction or implementation
phase of a Superfund site cleanup that follows remedial design.
Remedial Action Objectives (RAOs): Provide a general
description of what the cleanup will accomplish (for example,
restoration of groundwater to drinking water levels). These goals
typically serve as the as the basis for developing remedial
alternatives.
Remedial Design (RD): The development of engineering
drawings and specifications for the implementation and
construction of a remedial action.
Remedial Investigation (Rl): An investigation conducted to fully
characterize the nature and extent of contamination of a release,
or threat of release, of hazardous substances, pollutants, or
contaminants. In addition, the Rl also evaluate risks posed to
human health and the environment. The Rl gathers the necessary
data to support the corresponding FS.
Feasibility Study (FS) The FS is conducted after the Rl to
develop and evaluate remedial alternatives to address the risks
posed by the contamination at a site.
Response Action: A CERCLA-authorized action involving either
a short-term removal action or a long-term removal response. This
may include but is not limited to: removing hazardous materials
from a site to an EPA-approved hazardous waste facility for
treatment, containment or treating the waste on-site, identifying
and removing the sources of groundwater contamination and
halting further migration of contaminants.
Responsiveness Summary: A summary of oral and written
comments received by EPA during the public comment period on
EPA's Proposed Plan , and EPA's responses to those comments.
The responsiveness summary is a key part of the ROD,
highlighting community concerns for EPA decision-makers.
Superfund: The common name used for the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended in 1986.
22
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Figure 1. Site Location Map
Si to Boundary
TNs doo-mprl ntri OewtpK) m cctw «cpri>3ut»>cn K UV/ may no( topr* Jt«"« llw 0BH at nlprnJod
MAPL0CA1K5N
TRIANGLE PACIFIC
REMEDIAL INVESTIGATION
ELIZABETH CITY, NC
SITE LOCATION
A
0 500 1.000 2.COO 3.000 4.000
F«l
t7VI>
4.'JW
1:18.000
23
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Figure 2. Historic Facility Features
24
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Figure 3. Estimated Area of Soil Contamination
JrftcftfM Sol
Sanc*> Locjtcn
Mfro«r\j* Eoem
c< co-i
* 5*» kuuvy
ESTIMATEO EXTENT OF
SURFACE SOIL REMOVAL
FORMER TRIANGLE PACWIC SIIL
I LASIUim STUDY
LLIZALt !M CITY. MC
25
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Figure 4. Estimated Extent of Groundwater Contamination
26
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APPENDIX D
Letter from North Carolina Department of
Environmental Quality Supporting the Selected Interim Action
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ROY COOPER
NORTH CAROLINA
Environmental Quality
Governor
MICHAELS. REGAN
Secretary
MICHAEL SCOTT
Director
August 3, 2018
Mr. Jon Richards
Superfund Division
Restoration & Site Evaluation Branch
RPM & Radiation Support:
US EPA Region IV
61 Forsyth Street SW
Atlanta, Georgia 30303
RE: NC DEQ Concurrence for Interim Record of Decision (IROD), Triangle Pacific, Elizabeth City, NC
The State of North Carolina by and through its Department of Environmental Quality, Division of Waste
Management (herein after referred to as ''the state") has completed the review of the Interim Record of
Decision (IROD), Triangle Pacific. Elizabeth City, NC, and finds that it is acceptable as submitted subject
to the following conditions:
1. State concurrence is based solely on the information contained within the IROD received by the
Stale on July 20, 2018. Should the State receive new or additional information that significantly
affects the recommendations of this review, it may modify or withdraw this IROD concurrence
with written notice to EPA Region IV.
2. State concurrence of the referenced IROD in no way binds the State to concur in any future
decisions or commits the State to participate, financially or otherwise, in the cleanup of the site
referenced in this IROD. The State reserves the right to review, overview, comment, and make
independent assessment of ail future work relating to the site,
3. If, after remediation is complete, the total residual risk level exceeds 1G"6, the State may require
deed recordaiion/restrietion. to document the presence of residual contamination and possibly
limit future use of the property as specified in NCOS 130A-310.8.
The State appreciates the opportunity to comment on the IROD and looks forward to working with EPA
on the remedy for the subject site. If you have any questions regarding this concurrence or any other
matter concerning the site, please contact Kirsten HiortdaU at 919-707-8328 or at
Kirsten,HiortdithI@ncdenr.gov.
Sincerely,
James Bateson, LG, Chief
Superfund Section
Division of W aste Management
Cc: Qu Qi, NC Superfimd Branch Head
North Carolina Department of Environmental Quality J Division of Waste Management
217 West Jorics Street j Jfc+6 Mail Service Center 1 Raleigh. North Carolina ZJVW-SMfc
919,707.8200
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APPENDIX E
June 2018 Proposed Plan Public Comments and
EPA Responses to Comments
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DrinkerBiddle&^eath
LLP
Bonnie Ailvsi Barnetr
215 988 2916 Direct
215-988-2757 Fax
Botiaie Baf nett@dbr.com
l iin' Qfjkes
One Logan Squate
Suite 2000
Philadelphia ?A
19103-69%
2.15-^2700
2l5-m-27S7 frx
www .dtinkcfitiddlc^om
CAUFORNIA
DELAWAftfi
JUJNOiS
NiSW JERSEY
NEW YORK
PENNSYLVANIA
TEXAS
WASHINGTON d.c.
June 1, 2018
VIA E-MAIL AND CERTIFIED MAIL
Jon Richards
US EPA
Region 4
Superfund Division -11th Floor
61 Forsyth Street SW
Atlanta, GA 3030
Re: Triangle Pacific Corp. Superfund Site
Elizabeth City. North Carolina
Dear Mr. Richards:
On behalf of CBS Corporation and Armstrong Wood Products, Inc.. I am
attaching comments on the Interim Action Proposed Plan for the above-reference site.
ry truly yours,
Bonnie Allyn Ba:
BAB./jg
Via e-mail
cc: Bianca Jaikaran, Esquire
Michael Hall - OBG
John Aekiewiez
Dean Reed
William Wall, Esquire
Melinda Morrison, Esquire
iitfabihkd 1849
92778840,1
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Comments on the Triangle Pacific Interim Action Proposed Plan
Submitted on Behalf of CBS Corporation and Armstrong Wood Products, inc.
The Interim Action Proposed Plan ("Proposed Plan") prepared by the United States Environmental Protection
Agency (USEPA) has been reviewed by CBS Corporation and Armstrong Wood Products Inc. (collectively the
"Respondents1"). The Proposed Plan is based on more than 20 years of investigations performed at the
Triangle Pacific Site (Site) by the Respondents including a detailed Remedial Investigation (Rl), Human
Health Risk Assessment (HHRA), Baseline Ecological Risk Assessment (BERA), and Feasibility Study (FS), ali
of which have been approved by USEPA, While the Proposed Plan provides a reasonable summary of the
extensive work performed, there are several key considerations that affect remedial decision-making, and
the Respondents request USEPA's consideration of the following comments:
SUMMARY OF COMMENTS
1. The selection of any remedial action should be based on mitigating potentially unacceptable
risk to human health and the environment—As the Proposed Plan itself recognizes, an
assessment of risk "provides the basis for determining whether or not remedial action is
necessary and the justification for performing a cleanup " (Proposed Plan at page 8), The
National Contingency Plan, which implements the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), states: "The purpose of the remedy selection process is
to implement remedies that eliminate, reduce, or control risks to human health and the
environment" [40 CFR §300.430 (a) (1)]. Similarly, the North Carolina Risk-Based Remediation
Regulations, state that "Site-specific remediation standards shall be developed ... to reduce to
protective levels any substantial present or probable future risk to human health , , , and the
environment,[See N.C.G.S. §130A 310.65-310.77], These regulations are expressly applicable
to CERCLA sites and are, therefore an ARAR for the Site. [N.C.G.S. §130A 310.67 (a) (4)]. In short,
mitigation of unacceptable risk is and should be the driver for remedial action2.
2. The groundwater remedy selected in the Proposed Plan is not being driven by risk; the
risk assessments identified no unacceptable risks to human health under current or
reasonably anticipated future use at the Site—The Respondents performed detailed Human
Health ("HHRA") and Ecological Risk Assessments ("BERA") for the Site. As the Proposed Plan
recognizes, groundwater at the Site is not currently used for drinking (Proposed Plan at page 16)
and residential use, which could include groundwater as a drinking water supply, is not
considered a reasonably anticipated future use at the Site (Proposed Plan at page 10). In fact, the
Site is now zoned commercial except for a landfill, which is an unlikely location for homes, is
owned by the Respondents, and will be re-zoned as part of any remedy. Nonetheless, as described
in more detail below, the remedy selected by EPA assumes an unrealistic and "worse case"
residential use, where the groundwater is used for drinking. However, institutional controls,
ensuring the reasonably anticipated future use of the Site and addressing potential vapor risk in
one discrete area, is a sufficient remedy to address any hypothetical risk.
3. There are no unacceptable ecological risks at the Site except for two discrete surface soil
areas—The BERA identified two discrete areas of surface soil that drive potentially unacceptable
aggregate ecological risk at the Site. Those areas of surface soil will be properly removed as part
* Viacom Int., a Delaware corporation, was renamed CBS Corporation in 2005 and is the successor to CBS Corporation, the Pennsylvania
corporation that was signatory to the AOC and formerly known as Westlnghouse Electric Corporation, Armstrong Wood Products, inc., a subsidiary
of Armstrong World Industries, Inc., is the corporate successor to Triangle Pacific Corporation, which was also a signatory to the AOC.
2 The Proposed Plan does not take a consistent approach to risk, noting that "Any residua! contamination presenting an unacceptable risk to human
health and the environment will be addressed in the final remedy far the Site," hut also citing reduction to MCLs as a goal. See Proposed Plan at pages
2,12,15 and 19.
OBG | THERE'S A WAY ¦¦¦ PAGE t
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of the remedy. As discussed beiow, with the implementation of the proposed surface soil remedy,
the rezoning of the landfill and appropriate institutional controls, no potentially unacceptable
risks will remain at the Site. No further remedial work beyond the surface soil remedy will be
required to address ecological risks and the surface soil remedy should be considered a final, not
interim, remedy,
DETAILED COMMENTS
What follows are more detailed comments on the groundwater and soil remedies contained in the Proposed
Plan, followed by some additional clarifications.
Proposed Action for Groundwater
The Proposed Plan is inconsistent on the basis for remedial action in groundwater, it states, correctly, that
groundwater at the Site is not used for drinking water (page 16) but also states, incorrectly, that it is a current
and potential source of drinking water (page 6). The groundwater at the Site is not currently used for
drinking water, and institutional controls will restrict its use as a water supply.
Further, as stated on page 10 of the Proposed Plan, "...residential land use is not considered a reasonably
anticipated use." (Residential land use is an exposure scenario in which groundwater use as a drinking water
supply is contemplated.) Nonetheless, at the request ofUSEPA and NCDEQ, "...the HHRA included a residential
evaluation to provide a baseline, "worst-case" exposure scenario."
It is that hypothetical "worst case" scenario that forms the basis for the Proposed Plan's interim remedial
action, intended to address potential unacceptable risk from ingestion of groundwater (Proposed Plan at
page 19), Ingestion of groundwater would only be a concern for a hypothetical, residential use of the Site,
which is highly unlikely given conditions at the Site and the current commercial zoning, other than the landfill
which is under Respondents' control and which will be re-zoned, as noted in the Proposed Plan,
In short, the HHRA and BERA identify no unacceptable risk to human health and the environment associated
with ingestion of ground water under the current and reasonably anticipated future use of the Site, The HHRA
does identify a future potential risk of vapor intrusion from trichloroethylene (TCE) in one limited area of
the Site (around monitoring well MW-03) in the event that a building were constructed in this area. However,
this potentially unacceptable risk would be reliably and cost-effectively mitigated through the
implementation of institutional controls (Alternative 2) restricting construction in the affected area, or
requiring the installation of a vapor barrier or subslab mitigation system, No additional remedial action is
necessary to mitigate risk,
The Proposed Plan selects enhanced in-situ bioremediation and institutional controls (Alternative 3) in a
limited area of the Site, and suggests that the purpose is to reduce the concentration of TCE, as well as other
constituents that do not represent a risk and have not been identified as constituents of concern (COCs) in
the HHRA and BERA, to levels below the federal or state drinking water standards. This represents an
additional, redundant level of protectiveness once the use of groundwater for drinking Is restricted, and is
not consistent with the National Contingency Plan (NCP) and other regulatory requirements that remedial
action should be risk-based. In fact, the approved FS Report identifies the purpose of Alternative 3 as
reducing the TCE concentration to a level below that which represents a potential risk for vapor intrusion,
and presents a conceptual design and budgetary estimate that is consistent with this purpose. Alternative 3
was not developed for the purpose of, nor was its effectiveness (or cost) evaluated against the metric of
achieving drinking water standards.
It should also be noted that bioremediation was offered in the FS Report as a representative technology for
treatment, with limited data to support the potential efficacy of this approach. The Proposed Plan should
clarify that implementation of Alternative 3 would be contingent on the results of a treatability study, and
that other technologies may be more appropriate based on the results of the treatability study.
ORG J THERE'S A WAY
G
PAGE 2
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Proposed Action for Surface Soil
The proposed soil remedy is designed to reduce residual concentrations of certain COCs in two discrete
locations at the Site and thereby reduce the Site-wide aggregate ecological risk to acceptable levels. There
are several locations in the Proposed Plan (pages 2,19 and 20) that indicate that a "follow-up" ecological risk
assessment will be performed after completion of the interim action for surface soil. A 8ERA has already
been completed for the Site, and potential ecological risks have been clearly identified, The intent of the
remedial action is to remove the surface soil that drives the unacceptable aggregate potential risk to
ecological receptors.
Additional pre-excavation surface soil sampling will be performed surrounding the two areas for soil
excavation, and these data will be used to recalculate the potential aggregate terrestrial ecological risk for
the Site assuming removal of the soil within the iimits of these additional samples. As described below, it is
our intent to document this recalculation of risk in a work plan to be submitted to the USEPA and the North
Carolina Department of Environmental Quality (NCDEQ) for review and approval prior to soil removal. It is
our expectation that this would be sufficient to document the mitigation of risk that would be accomplished
by the soil removal, and that no "follow-up" risk assessment will be required, Moreover, removal of soil
consistent with the work plan should be considered a final and not interim remedy for soil.
In order to streamline remedial implementation, facilitate USEPA and NCDEQ review of the revised risk
calculations, and avoid the need for additional mobilizations for soil removal, we suggest the following
modification to the sequence for the proposed interim remedial action (Proposed Plan at p3ge 19):
1. Perform additional sampling of the surface soil in the two areas of elevated concentrations.
2. Recalculate aggregate terrestrial ecological risk using the additional samples and the remaining
Site surface soil dataset, to identify the extent of excavation to reduce the potential risk to
acceptable levels. Additional sampling will be performed, as necessary, to identify the extent of
excavation to achieve this objective.
3. Document the revised risk calculations in a work plan that identifies the extent of surface soil
removal, and submit this plan to the USEPA and NCDEQ for review and approval
4. Perform the surface soil removal as necessary. Dispose of the soil offsite at an appropriately-
permitted facility, and backfill the excavation with certified clean fill.
5. Document the removal and disposal of the soil in a remedial action completion report, to be
submitted to the USEPA and NCDEQ,
Final Remedies
It is important to note that remedies beyond the surface soil remedy and institutional controls would not be
needed if North Carolina's Risk-Based Statutes are applied at the Site, The risk assessments performed by
Respondents are consistent with the requirements of the North Carolina Risk-Based Remediation Program
and would support a risk-based remedial approach.
The Proposed Plan presumes that additional remedial activities will be required, but does not provide a clear
or consistent description of why a final remedy may be necessary, The introduction to the Proposed Plan
states that "Any residual contamination presenting an unacceptable risk to human health and the
environment will be addressed in the final remedy for the Site", and we concur with this statement, and
believe that the remainder of the Proposed Plan should reflect this. The proposed remedial action for surface
soil, if implemented as described above, will result in mitigation of the unacceptable potential risk to
ecological receptors, and should, therefore, constitute an appropriate final remedy. Similarly, application of
a risk-based approach, whether under CERCLAor North Carolina's Risk Based Remediation Statutes, coupled
with rezoning of the landfill and institutional controls, suffice for a final groundwater remedy at the Site,
0BG s THtSE'S A WAY
PAGE J
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Other Items
The following specific comments are provided as clarification/correction to the Proposed Plan:
1. The terms COCs and constituents of potential concern (COPCs) appear to be used interchangeably
throughout the Proposed PSan. These are not equivalent, and the Proposed Plan should be
reviewed to verify the proper term is being used.
2. Tables 1 and 2 in the Proposed Plan provides a list of COCs that is not consistent with the COCs
identified in the HHRA.
3. The poiychlorinated biphenyls (PCBs) Subsection in Section 5 refers to various Aroclor
exceedances of human health and ecological screening values in surface soil, and refers to Figure
3, which provides no references to PCB exceedances.
OBG j THERE'S A WAV
PAGE 4
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EPA responses to Public comments:
Responses to the 6/7/18 comments from C'BC Corporation and Armstrong Wood Products.
Inc.. [the Potential Responsible Parties!:
Public Comment #1. Remedy Selection:
This comment is answered in part 1 of response to comment #2 below:
Public Comment #2. Groundwater Responses:
1. Proposed Action for Groundwater-page 2 of Detailed Comments:
Comment: The letter states that the Proposed Plan has incorrectly identified the groundwater at
the Site a.s a current and potential source of drinking water.
Response: The mission of the Superfimd program is to protect human health and the
environment consistent with the Comprehensive Environmental Response. Compensation, and
Liability Act of 1980 (CERCLA), as implemented by the National Oil and Hazardous Substance
Pollution Contingency Plan (NCP). in part by restoring contaminated groundwaters to beneficial
use. EPA has well-established policy, supported by regulation, that specifies the expectation for
remediation of groundwater that is considered a potential source of drinking water, regardless of
current land use. Federal Register Volume 55 Number 46 page 8732 states the goal of EPA's
Superfimd program regarding groundwater contamination as follows:
The goal of EPA's Superfimd approach is to return usable ground waters to
their beneficial use within a timeframe that is reasonable given the particular
circumstances of the site.
Additional language in the Federal Register supports EPA's intention to remediate groundwater
regardless of the current or even anticipated future exposure scenarios. Federal Register Volume
55 Number 46 page 8753 presents the following language regarding EPA's approach to
groundw ater contamination at Superfimd sites:
CERCLA... Sect ion 104(c)(6) reflects Congress's expectation that ground
w ater should be restored to protective levels. If ground w ater can be used
for drinking water. CERCLA remedies should, where practicable, restore
the ground water to such levels.
The preamble to the National Oil and Hazardous Substances Pollution Contingency Plan
(Federal Register Volume 55 Number 46 page 8732) states:
EPA's Superfimd program uses EPA's Ground-Water Protection Strategy
as guidance when determining the appropriate remediation for contaminated
ground water at CERCLA sites. EPA's Ground-Water Protection Strategy
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establishes different degrees of protection for ground waters based on their
vulnerability. use. and value...The Super!bud remedial process assesses the
characteristics of the affected ground water as the first step in deciding the
remediation goal for ground-water restoration... A determination is made as
to whether ground water falls within Class I. II. or III. Guidance for making
this determination is available in "EPA Guidelines for Ground-Water
Classification" (Final Draft. December 1986).)
The default classification of groundwater is Class lib. which is considered as "...potentially
usable as a source of drinking water..(EPA Guidelines for Ground-Water Classification under
the EPA Ground-Water Protection Strategy, page 20). EPA has determined that for the Triangle
Pacific site, there is no technical basis for a determination the groundwater does not meet the
definition of a Class IIB groundw ater.
Furthermore, the 1986 Superfund Amendments and Reauthorization Act (SARA) adopts and
expands a provision in the 1985 National Contingency Plan (NCP)that remedial action must at
least attain applicable or relevant and appropriate requirements (ARARs), CERCLA Section
121(d) requires attainment of Federal AR.ARs. and of State ARARS when the requirements are
promulgated, more stringent than Federal laws, mid identified by the State in a timely manner.
See US EPA .ARARs Q*s and A*s. OERR 9234.2-01FS, May 1989. The State of North Carolina
2L Water Quality Standards, promulgated for the protection of the groundwaters of the state, are
the maximum allowable concentrations resulting from any discharge of contaminants to the land
or waters of the state which may be tolerated without creating a threat to human health or would
otherwise render the groundwater unsuitable for its intended best use. See 15A NCAC 02L.
0202. The State of North Carolina classifies all groundwaters located w ithin the boundaries of
the state which contain 250 mg 1 or less of chloride as Class GA groundwaters; potential source
of drinking water supply for humans. See 15A NCAC 02L .0201. In this case. NC classifies the
best use of groundwater at the Triangle Pacific Site as a potential source of drinking water supply
for humans, and as such, these waters must attain 2L standards as applicable or relevant mid
appropriate requirements .
EPA has followed the defined intent of groundwater restoration cited in Federal regulations and
supporting procedures in the regulations, to evaluate potential remedial actions to address site
groundwater contamination. EPA's process for evaluating groundwater remedial actions for the
Triangle Pacific site is consistent with established approaches that are supported by EPA
regulations, policy, and technical guidance.
2. Proposed Action for Grouiidwiiter-piige 2 of Detailed Comments;
Comment: The letter .states the approved FS Report "... identifies the purpose of Alternative 3 as
reducing the TCE concentration to a level below that which represents a potential risk for vapor
intrusion...
Response: Page 15 of the approved Feasibility Study Report identifies as a remedial action
objective (RAO) for groundwater the restoration of groundwater quality to the extent practicable
to meet NCDEQ and US EPA primary drinking water standards throughout the plume. EPA
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concurs with this stated goal and lias proposed an interim remedial action for groundwater
consistent with this RAO. albeit an interim action that is not intended to fully meet the RAO.
Restoration of groundwater to its beneficial use as a potential drinking water source, and
attainment of Federal MCLs and North Carolina's 2L Water Quality Standards, is a stated goal
of the final Remedial Action that will be documented in a future Record of Decision (ROD),
3. Proposed Action tor (> rou 11 <1 w a te r- p a ge 2 of Detailed Comments:
Comment: The letter states "... bioremediation was offered in the FSReport as a representative
technology for treatment, with limited data to support the potential efficacy of this
approach. The Proposed P km should clarify that implementation of Alternative 3 would
be contingent on the results of a treatability study, and that other technologies may be
more appropriate based on the results of the treatability study. "
Response; EPA lias not selected a final remedial action for groundwater. EPA considers the
enhanced in-situ bioremediation remedial option included in the approved Feasibility Study
Report as having a reasonable possibility of achieving the groundwater RAO. Application of the
enhanced in-situ bioremediation as an interim action presents an opportunity to refine the
remedial approach that would be implemented as the final groundwater remedial action for the
site.
Public Comment #3. Ecological Response:
Summary of Comments, Comment #3: Addressing the statement that ecological risk at the site
is not justifiable in its current form based on EPA ecological guidance: For this IROD. in the
areas of the Site that were investigated, the only identified areas of unacceptable ecological risk
are two discrete surface soil areas, which will be addressed with the hot spot removal rented)
proposed.
Proposed Action for Surface Soil [P.4 of 5]: The IROD plan is reasonable for addressing the
risk that was identified and EPA be Hexes the proposed surface soil sampling right around the
areas to be excavated can be used for the data from these for projecting the resulting post-
removal risk. The potential eco risks were identified as caused by the soil contaminant
concentrations but also by the soil invertebrate prey tissue contaminant concentrations, so if
future ecological assessment for the final ROD is needed, the PRPs could probably take prey
item (soil invert) tissue samples as well to use in their risk calculations. This can be decided as
part of the final remedy discussion.
Final Remedies response:
This will be addressed as part of the Final ROD for this site.
Other Items response:
1. The COC and CO PC terms have been clarified in the IROD in Sec. 4. and will be further
defined as a part of the later Final ROD
2. Tables 1 and 2 in the Proposed Plan, identified all COCs that exceed a MCL or NC 2L levels
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3, The PCB levels, if they exceed human health or ecological clean up levels, will be decided as
part of the Final ROD.
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