NCD095458527_19941101_FCX Inc. (Statesville)_FRBCERCLA ROD_Record of Decision OU-2-OCR

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FCX-STATESVILLE
SUPERFUND SITE
RECORD OF DECISION
OPERABLE UNIT TWO
RECEIVED
OCT 2 0 1997,
SUPERFUND SECTION
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
NOVEMBER 1994
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DECLARATION
FOR
THE RECORD OF DECISION
SITE NAME AND LOCATION
FCX-Statesville
Statesville, Iredell County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Operable Unit Two Remedial
Action for the FCX-Statesville Superfund Site (the "Site") in
Statesville, Iredell County, North Carolina, chosen in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of• 1980, as amended by the Superfund Amendments and.
Reauthorization 'Act of 1986 and, to the extent practicable, the
National Contingency Plan. The main objectives of the Operable
Unit Two Remedial Action will be to reduce the risks associated
with Site-related contamination in the surface soil, as well as
reduce the amount of total pesticides in the surface and subsurface
soil as a source of groundwater contamination. This decision is
based on the administrative record file for this Site.
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The State of North Carolina concurs with the selected remedy for
Operable Unit Two. All comments submitted to EPA during the public
comment period, as well as EPA's responses to those comments, can
be found in Appendix A of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Operable Unit Two Remedial Action addresses the soil
contamination at the Site. The major components of the Operable
Unit Two Remedial Action include:
*
*
demolishing the existing buildings and structures, and
transporting the demolition rubble to an appropriate
disposal facility;
excavating approximately 6,945
contaminated soil, and stockpiling
preparation for treatment;
\
cubic yards of
the soil on-site in
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* treating the contaminated soil on-site using thermal desorption and.base.catalyzed decomposition;
* backfilling the excavated areas with the treated soil; and
* regrading and seeding the Site with grass to minimize the potential for erosion and to enhance the appearance of the Site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health environment, complies with Federal and State requirements legally applicable or relevant and appropriate to the Action, and is cost-effective.
and the
that are
Remedial
This remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable, and satisfies the statutory preference for remedies t~at employ treatment that reduces toxicity, mobility, or volume· of Site contaminants as a principal element.
~\.,.~~ Richard D. Green, ASS()iate Director Date Office of Superfund and Emergency Response
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Description
I. SITE
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B.
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II. SITE
A.
B.
FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
TABLE OF CONTENTS
NAME, LOCATION, AND DESCRIPTION
Introduction
Site Descri12tion
To1209:ra12hy
Geol0£1::iLHydrog:eolo£1::i
Surface Water
Meteorolo£1::i
Demog:ra12hy and Land Use
Utilities
HISTORY AND ENFORCEMENT ACTIVITIES
Site Histo!Ji:
Enforcement Activities
I I III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Page
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IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY 7
v. SUMMARY OF SOIL INV'E~TIGATION
Phase I Results .
Phase II Results
VI. SUMMARY OF SITE RISKS
A. Chemicals of Concern
B. Ex12osure Assessment .
C. Toxicity Assessment.
D. Risk Characterization
Current Land Use
Future Land Use ...
E. Environmental (Ecological) Assessment
VII. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
A. Action-S12ecific ARARs .
B. Location-S12ecific ARARs
C. Chemical-S12ecific ARARs
VIII. REMEDIAL ACTION OBJECTIVES
IX. DESCRIPTION OF ALTERNATIVES
Alternative 1: No Action ..
Alternative 2: Limited Action
Alternative 3: Demolition of Buildings and Capping
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
Description Page
Alternative 4: Soil Excavation and On-Site Treatment
Using Thermal Desorption and Base Catalyzed
Decomposition. . . . . . . . . . . . 25
Alternative 5: Soil Excavation and On-Site Treatment
Using Thermal Desorption and an alternate method
of treating offgases . . . . . . . . 25
Alternative 6: Soil Excavation and Off-Site Treatment
Using Inciner~tion . . . . . . 25
X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Threshold Criteria. . . . ....
Overall Protection of Human Health
and the Environment
Compliance with ARARs ..
Primary Balancing Criteria ....
Short-term Effectiveness . /.
Long-term Effectiveness and_•Permanence
Reduction of Toxicity, Mobility, or Volume
Implementability
Cost . . . . . .
Modifying Criteria .. ,
State Acceptance
Community Acceptance
XI. THE SELECTED REMEDY ....
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XII. STATUTORY DETERMINATION 47
Protection of Human Health and the Environment 49
Compliance with ARARs 49
Cost Effectiveness . . . . . . . . . . 49
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable 49
Preference for Treatment as a Principal Element .... 49
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Description
FIGURE
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
LIST OF FIGURES
DESCRIPTION
Site Diagram (prior to the late 1960s)
Site Diagram (after the late 1960s)
Soil Sample Locations .
DDT Distribution in Soil.
i Areas of Contaminated Soil to.be Remediated
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Description
TABLE
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
LIST OF TABLES
DESCRIPTION'
Model for Calculating Doses from
Dermal Contact with Soil.
Model for Calculating Doses from Incidental
Ingestion of Soil. . . . . . . . .
Exposure Point Concentrations for
Chemicals of Concern (mg/kg).
I I Toxicity Values for Chemicals .•of Concern.
Carcinogenic and Non-Carcinogenic Risk
Levels for Chemicals of Concern.
Analysis of Federal ARARs.
Analysis of State of North
Carolina ARARs. · . .
Soil Remediation Levels ..
Evaluation of Remedial Alternatives.
Cost Estimate for Alternative 4 ...
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I. SITE-NAME, LOCATION, AND DESCRIPTION
A. Introduction
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 1
The FCX-Statesville property is located at the intersection of Phoenix Street and West Front Street (Highway 90) approximately 1.5 miles west of downtown Statesville. Beginning around 1940, Farmers Cooperative Exchange (FCX) began operations as an agricultural distribution center. These operations included the formulation, repackaging, warehousing·, and distribution of farm chemicals, -primarily pesticides and fertilizers, along with the milling and sale of feed grains. The repackaging of liquid pesticides was discontinued in 1966 and dust repackaging in 1969.
Testimony from previous employees indicates that 5,000-10,000 pounds of pesticides may have been buried on-site during the late 1960's or early 1970's. Pesticide contamination in the soil, as well as pesticide and volatile organic compound (VOC) contamination in the groundwater, have been identified at the Site since 1986.
B. Site Description f
The Site is approximately 5.5 acres i'n size. The coordinates of the Site are latitude 35° 47' 11" north, longitude 80° 54' 58" west. The Site is bounded to the north by the Norfolk-Southern Railroad and Burlington Industries (formerly Beaunit Mills), the Carnation ._Milk Company property to the west, residential and small business property along the south side of west Front Street, and a pre-fabricated utility and sales lot on the east side of Phoenix · Street. Prior to the late 1960's, the main structures at the Site included a U-shaped building used for pesticide operations, and several buildings on the eastern half of the property used for the milling and bagging of feed grains. A small office building was also present near the southeastern corner of the property. Figure 1 shows the Site as it existed prior to the late 1960's.
During the late 1960's, most of the buildings on the property (with the exception of the small office building) were demolished. Since that time, several buildings and paved areas have been constructed to replace the original structures. A large brick warehouse was constructed around 1969-70, and a smaller, metal warehouse painted blue was constructed in 1982. An asphalt parking lot was paved between the warehouses and West Front Street. The majority of the Site to_ the east of the-two warehouses is a gravelled area, and contail\§.__a large reinforced concrete slab and smaller concrete tractor trailor pads. Figure 2 shows the Site as it exists today.
CARNATION
MILK COMPANY " I
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RESIDENTIAL
AREA
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SJ:TB DJ:AGRAK1960'a) t late (prior 0
FCX-STA ITSVILcLJRoUNA E NORTH STA TESVILL , APPROXIMATE ~;/LE'"
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1-- --,,....--,, CARNATION MILK COMPANY --/ , / , j i11vo ,, ----,.---~ .. BURLINGTON INDUSTRIES ---B D l!!>s,-""~ o,v,. ~(;> C S1;,;, RESIDENTIAL AREA FrGURB 2 srTB DrAGRAM (after l~te 1960•aJ· (SHO\\SNG _ON-SllE MONITORING WELLS) FCX-STA TESVILLE STATESVILLE. NORTH CAROLINA <'e,-,· ~ • as.. ~ ~~"" ~ ... ~ -y ~'.lo ~I<...._ .... .. ~I I (/) .,,. >< ~ GATE ~ • /) l OFFICE APPROXIMATE SCALE 125 o n., 12, ( IN f't[T ) 1 Inch • 125 ft. ~ _ __, ' ' --◊ ----l!£l 8 -MONITORING YIO.J.S ~EPA - -.--···,., cl "' ' <n ;l z ..ao '"< "'ro ;S g. ~ r ro z "ti C" '1 > ,. '" r " ~ MO 1.0 ;:ti c~o w i,.) .i:. a -
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C ;'--· Topography
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November 1994
FCX-STATESVILLE OU2
PAGE 4
The Site is situated in the Piedmont physiographic province in
western-central North Carolina. The Piedmont physiographic
province is characterized as gently rolling and sloping, with
slopes on-site ranging up to 1.5 percent. Slopes in the immediate
vicinity of the Site range from 2 to 6 percent. Elevations within
a four-mile radius of the Site range from 740 to 970 feet above
mean sea level.
D. Geology/Hydrogeology
The Site lies within the geologic belt known as the Blue Ridge-
Inner Piedmont Belt. The Blue Ridge-Inner Piedmont Belt generally
consists of metamorphic rocks including gneisses and schists, as
well as gradations of the two types. Most of these rocks near the
surface have weathered irtto a layer of "overburden" overlying the
fractured but relatively unweathered bedrock. The overburden
ranges in thickness from 15-40 feet at the Site, and consists of
saprolite and residual soils interspersed with unweathered
gneiss/schist, and to a lesser extent, alluvium. Granitic
intrusions are also common in the areal of the Site. Soils in the
general area of the Site belong to the Lloyd Association. These
soils, located along broad ridges with short side slopes, are
characterized as deep, well-drained soils with a subsoil of dark
red clay.
Groundwater at the Site occurs in an unconfined-to-semiconfined
aquifer consisting of the overburden hydraulically interconnected
with the underlying fractured bedrock. The saturated overburden
serves as a groundwater reservoir which supplies water to the
fractures, faults, and other secondary permeability features in the
bedrock. Approximate depth to groundwater in the saturated
overburden in the vicinity of the Site generally ranges from 27 to
30 feet below land surface. During the wetter periods of the year,
groundwater may intersect the ground surface and become overland or
surface water flow.
E. Surface Water
On-site surface water drainage and flow patterns are generally
controlled by topography and several man-made drainage structures
constructed along West Front Street and Phoenix Street. Surface
water flow is generally to the south into Free Nancy Creek, which
converges with Third Creek approximately 1.5 miles southeast of the
Site (two miles stream distance). Third Creek flows in a easterly
direction for approximately 15 miles, where it empties into the
South Yadkin River.
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F :· ·. Meteorology
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE· 5
The climate in Iredell County is classified as fairly mild, and is influenced by the mountain ranges to the northeast, and the Atlantic Ocean to the southeast. Prevailing winds are from the southwest, although northeast winds do frequently occur in the autumn. Relative humidity averages about 70 percent throughout the year. Monthly total precipitation generally ranges from about 3 inches during October and November to about 5 inches during July and August.
G. Demography and Land Use
The Site is located along an industrial corridor which stretches along West Front Street. The area around the Site is characterized by a combination of light/heavy industry, commercial, residential, and institutional. The ·estimated population within the five-mile radius of the Site includes all of Statesville (18,622 in the 1980 census) and an estimated 9,500 living in Iredell County outside the city limits. The population within the three-mile radius of the Site includes about 90% of the city's population (about 17,000 people) and 2,440 county residents. _/
H. Utilities
Electricity, telephone, as well as water and sewage connections .have been terminated since FCX · declared bankruptcy in 1986. Nevertheless, these utilities are available upon request.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
FCX began operating the Site as an agricultural supply distribution center about 1940 and continued to operate the Site until declaring bankruptcy in 1986. The Site served as a formulating, repackaging, warehousing, and distribution center for pesticides, fertilizers, and feed grains. The repackaging of liquid pesticides was discontinued in 1966 and dust repackaging in 1969. As stated in the Introduction, 5,000-10,000 pounds of the pesticides DDT, DDE, and chlordane were allegedly disposed of. on-site in two trenches, buried under six feet of soil, and later covered with a reinforced, 8"-thick concrete slab and warehouse.
Previous investigations conducted prior to the Remedial Investigation at the FCX Site have been conducted by Fred C. Hart for Southern States Cooperative, by the North Carolina Department of Human Resources (NCDHR) (now known as the North Carolina Department of Environment", Health, and Natural Resources (NCDEHNR)
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FCX-STATESVILLE OU2
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Superfund Section), and by EPA-Region IV Emergency Response. The following paragraphs briefly summarize the soil sample results of these investigations.
The Fred C. Hart investigation in February 1986 ~esulted from a pre-purchase environmental evaluation on behalf of Southern States Cooperative. Five composite soil samples were collected to investigate the soil for reported pesticide contamination. Analytical results of the soil samples indicated the presence of nine pesticides, most notably chlordane and DDT.
The NCDHR conducted a Site Inspection in May 1986. Soil samples were collected both on-site and off-site in the front yard of an adjacent residence. Analytical results of the soil samples indicated the presence of pesticides both on the FCX property as well as on the adjacent property.
EPA-Region IV Emergency Response conducted emergency sampling investigations at the Site in January 1989 and again in January 1990. Extensive exploratory borings were drilled through the main warehouse concrete floor in an attempt to locate the alleged pesticide trenches. Efforts to locateithe pesticide trenches were unsuccessful.
B • Enforcement Activities
. on September 17, 1986, FCX filed a voluntary petition under the· provisions of Chapter 11 of the United States Bankruptcy Code. The EPA, NCDEHNR, and FCX entered into a settlement agreement, whereby FCX established a trust to be used to remediate the Site.
The FCX-Statesville Site was evaluated using the Hazard Ranking· System (HRS). The Site was proposed for inclusion on the National Priorities List (NPL) on June 24, 1988, and was finalized on the NPL on February 21, 1990. EPA-Region IV initiated RI/FS field activities at the Site in June 1991 with the aid of EPA's Environmental Services Di vision, and EPA' s Alternative Remedial Contract (ARCs) contractor, Roy F. Weston.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Pursuant to Section 113(K) (2) (B) (i-v) and Section 117 of CERCLA 42 U.S.C. § 9613 (K) (2) (B) (i-j), and 42 U.S.C. § 9617, the Community Relations Plan and the RI/FS Reports were made available' to the public irlthe Administrative Record located both in the Information Repository maintained at the EPA Docket Room in Region IV and at the Iredell County Library in Statesville, North Carolina. Fact sheets notifying local citizens about the availability of these documents, explaining the RI/FS process, and summarizing site-
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November 1994
FCX-STATESVILLE OU2
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related,,activities were sent out in May 1991 and April 1993. A
public meeting was held on May 31, 1991 to inform citizens about
upcoming RI activities. · Notices of the Proposed Plan public
meeting were published in the Record and Landmark and the Iredell
County News on July 5, 1994. A 30-day public comment period was
held from July 5, 1994 to August 4, 1994. The Proposed Plan public
meeting was held on July 11, 1994 where representatives from EPA
answered questions about the Site and the remedial alternatives
under consideration. The public requested an extension of the
comment period during the meeting. Based on this request, EPA
extended the comment period through September 3, 1994.
Representatives from EPA have met with individual citizens and
citizen groups on numerous occasions over the past several years to
obtain their input and to keep them informed. The local citizens
group "Citizens for a Clean Environment" applied for and were
awarded a Technical Assistance Grant (TAG) on March 23, 1992.
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
As with many Superfund sites, the FCX-itatesville Site is complex.
For this reason, EPA currently believes that the remediation of the
Site will be accomplished most effectively by implementing three
phases of cleanup, referl'.'ed to as "operable units".
,Each operable unit requires a. separate RI/FS, Risk Assessment,
Proposed Plan, and Record of Decision. The objectives of the three
operable units (OUs) at the Site are:
OU One: Address .the groundwater contamination beneath the
FCX property and to the south of the FCX property;
OU Two: Address the pesticide soil contamination on the FCX
property; and
OU Three: Address all other contamination associated with the
property which is currently owned and operated by
Burlington Industries.
The Record of Decision for OU One was signed by the EPA-Region IV
Acting Regional Administrator in September 1993. EPA is currently
developing the work plan to design the groundwater pump-and-treat
system for OU .One. Once the Regional Administrator has signed the
Record of Decision for OU Two, EPA will hire a contractor to
developa work plan to design the soil remediation system. On
April 25, 1994, EPA held a public meeting in Statesville to
initiate the Remedial Investigation field activities for OU Three.
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November 1994
FCX-STATESVILLE OU2
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Once this investigation is complete, EPA will write the Record of
Decision for OU Three to address the contamination associated with
the property currently owned and operated by Burlington Industries.
V. SUMMARY OF SOIL INVESTIGATION
Soil samples were collected and analyzed throughout the Remedial
Investigation (RI) in order to fully characterize the nature and
extent of the soil contamination at the Site. All of the soil
samples collected during the RI were analyzed for Target Analyte
List (TAL) metals, cyanide, Target Compound List (TCL) voes, Semi-
Volatile Organic Compounds (SVOCs), poly-chlorinated biphenyls
( PCBs) , and pesticides. Numerous exploratory borings were also
drilled during the RI in an attempt to locate the alleged pesticide
burial trenches.
During the Phase I RI conducted in June 19 91, one hundred and
eighty-seven (187) surface and subsurface soil samples were
collected from three areas on and around the FCX property. Area 1
includes the residential area south of Front Street, the Carnation
property, and locations adjacent to ahd east of Phoenix Street.
Area 2 includes those portions of the'FCX property not covered by
the warehouses, as well as locations adjacent to the railroad
tracks. Area 3 includes those locations presently under the
warehouses. Figure 3 shows the soil sample locations. During the
.-Phase II RI conducted in -June 1992, nine (9) soil samples were
collected and analyzed to provide additional information regarding
surface and subsurface soil contamination at the Site.
Phase I Results
A number of .metals were detected in the soil samples during the
Phase I RI, most commonly aluminum, iron, chromium, lead, vanadium,
barium, magnesium, potas$ium, nickel, calcium, zinc, copper, and
cobalt. Most of these metals, based on their widespread occurrence
and geological/mineralogical associations, are probably present at
naturally-occurring concentrations. However, chromium and lead
were detected in several samples at concentrations significantly
higher than naturally-occurring or background concentrations. The.
elevated levels of chromium and lead in these samples are not
thought to be associated with former FCX operations.
Thirteen pesticides were identified in surface and subsurface soil
samples _ _g_ollected and analyzed during the Phase I RI. These
pesticides included DDT, DDD, DDE, pentachlorophenol, alpha-
chlordane, gamma-chlordane, dieldrin, endrin, heptachlor,
heptachlor epoxide, alpha-BHC, gamma-BHC (lindane), and aldrin.
The most widespread pesticides detected in the soil were the
compounds of the DDT family (4,4'-DDT and its degradation or
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BURLINGTON INDU::; fRIES
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FIG11RB 3
SOIL SAMPLE LOCATIONS AND DEPTHS
FCX-STATESVILLE REMEDIAL INVESTIGATION
STATESVILLE, NORTH CAROLINA
JUNE 1991 TO SEPTEMBER 1991
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 10
transformation products, 4,4'-DDD and 4,4'-DDE), DDT (4,4'-DDT) was
detected in fifty-seven (57) out of one hundred eighty-seven (187)
samples collected. Figure 4 shows the distribution of DDT in the
soil, including the detection boundary, as well as the 1,000 ug/kg,
10,000 ug/kg, and the 100,000 ug/kg isoconcentration boundaries.
The highest concentration of DDT detected in the soil during the
Phase I RI, 830,000 ug/kg, was detected from 12-16 inches below the_
surface at sample location FS-319-SLB.
The soil sample results from the Phase 1 RI indicated presumptive
evidence of dioxin and furans. As a result, an additional forty-
three ( 43) soil samples were collected from twenty-two sample
locations and analyzed for dioxin and furans, Dioxin was present
in the soil beneath the upper warehouse at Toxicity Equivalent
Quotient (TEQ) concentrations below· one part-per-billion. EPA also
collected groundwater samples from a representative number of the
on-site monitoring wells to determine if dioxin or furans had
leached from the soil into the groundwater. None of the
groundwater samples revealed the presence of dioxin or furans,
A number of extractable organic compounds were identified in the
soil samples collected_ and analyzed dJring the RI. Nineteen (19)
of the twenty-one (2i) extractable organic compounds were
polycyclic aromatic hydrocarbons (PAHs), including pyrene,
fluoranthene, anthracene, perylene, phenanthrene, benzo-
(b/k)fluoranthene, chrysene, benzo(a)anthracene, benzo(a)pyrene,
.indeno(l,2,3-CD)pyrene, and dibenzo(A,H)anthracene. The elevated
levels of PAHs in the soil are not thought to be associated with
former FCX operations, but with the cross ties underlying the
railroad tracks next to the Site. In addition to the extractable
organic compounds mentioned in the previous paragraphs, forty (40)
additional extractable compounds (listed as mostly unidentified
compounds) were detected·during the Phase I RI.
Twelve (12) purgeable organic compounds were also detected in soil
samples collected and analyzed during the Phase I RI. Of these
twelve compounds, trichloroethene and tetrachloroethene were the
most frequently detected in the soil. The distribution of these
two compounds -in the soil appears to coincide with the plume of
trichloroethene and tetrachloroethene in the groundwater. Other
purgeable organic compounds identified at small concentrations in
the soil during the RI included acetone, 1,2-dichloroethene,
tetrahydrofuran, chloroform, total xylene, ethyl benzene,
chlorobenzene, pinene, trimethylcyclohexane, and ethylmethyl-
cyclohe;:.ane.
Phase II Results
Six of the nine soil samples collected during the Phase II RI were
analyzed to provide total organic carbon (TOC) values for
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 12
evaluat-ing the fate and transport of the Site contaminants. Two
soil samples, FS2-Tll-SLA and FS2-Tll-SLB, were collected from the
20-25 foot depth interval and the 30-35 foot interval,
respectively. Both samples contained DDT, DDD, DDE, and gamma-
chlordane at concentrations up to 20 ug/kg, as well as several BHC
isomers, endrin, and heptachlor at concentrations below 20 ug/kg.
VI. SUMMARY OF SITE RISKS
The Baseline Risk Assessment (BRA) was developed to identify the
potential threats to public health and the environment posed by the
Site under current and future conditions, assuming that no remedial
actions take place, and that no restrictions are placed on future
use of the Site. The results of the BRA indicate that actual or
threatened releases from the Site, if not addressed, may present an
imminent and substantial endangerment to human health and the
environment.
The BRA evaluated the potential risks from exposure to contaminated
surface soil, surface water, sediment, and groundwater. Any
potential risks associated with contartlinated groundwater will be
addressed with Operable Units One and Three. However, the specific
objective of Operable Unit Two is to address contaminated soil on
the FCX property. The following sections summarize the· Site-
related risks as they relate to the following topics: A) chemicals
.. of concern, B) exposure assessment, C) toxicity assessment, D) risk
characterization, and E) environmental (ecological) assessment.
A. Chemicals of Concern
In order to identify potential chemicals of concern for the Site,
the chemicals present in Site samples were screened using
comparisons with ambient or background concentrations, essential
nutrient concentrations, as well as concentration-toxicity
criteria. If a chemical of potential concern was determined to
contribute significantly to an unacceptable risk, and was not
screened out using these comparisons, then it was considered to be
a chemical of concern at the Site.
The chemicals of concern identified in the soil at the FCX-
Statesville Site included arsenic, beryllium, benzo(a)pyrene,
dibenzo(a,h)anthracene, benzo(b,k)fluoranthene, pentachlorophenol,
and dioxin. Several of .these chemicals of concern, such as the
inorganics arsenic and·beryllium, are not thought to be associated
with former FCX operations. Therefore, these inorganics will not
be targeted for remediation during Operable Unit Two. Likewise,
the following PAHs, benzo (b, k) f luoranthene, benzo (a) pyrene,
dibenzo (a, h) anthracene, are not thought to be associated with
. former FCX operations. These PAHs are "creosote-related" compounds
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November 1994
FCX-STATESVILLE OU2
PAGE 13
which are.commonly found in the crossties which underly railroad
tracks. Therefore, these PAHs will not be targeted for remediation
during Operable Unit Two.
Dioxin was identified in the surface soil at levels less than one
part-per-billion (or 1. 0 ug/kg) TEQ. The draft dioxin reassessment
document has recommended a minor relaxation of the Cancer Slope
Factor (CSF) for Dichloro-Diphsdyl-Trichloromethane (TCDD) and has
not recommended a Rfo· for use in evaluation of non-cancer
endpoints. Using the new CSF and standard default daily exposure
assumptions, 1.0 ug/kg of dioxin TEQs in soil equates to an upper
bound risk estimate of about 10-•. The 1.0 ug/kg level will likely
continue to be considered by EPA as the residential protective
level during the reassessment finalization period to be completed
in September 1995. For this reason, dioxin will not be targeted
for remediation during Operable Unit Two.
B. Exposure Assessment
The exposure assessment uses the description of the Site and the
soil contamination characterized during the Remedial Investigation
to identify potential exposure pathways for the contaminants of
concern.
The exposure pathways that were evaluated under the current land
use conditions were: the dermal contact and incidental ingestion of
. surface soil by children. and adults living in Area l; and the
· dermal contact and incidental ingestion of surface soil by an
adolescent child trespassing into Areas 2 and 3.
The exposure pathways that were evaluated under the future land use
conditions were: the dermal contact and incidental ingestion of
surface soil by children and adults living on-site (assuming the
existing· buildings and parking lots were removed); the dermal
contact and incidental ingestion of surface soil by the on-site
worker (assuming the existing buildings remain); and the dermal
contact and incidental ingestion of surface soil by the on-site
worker (assuming the existing buildings were removed).
C. Toxicity Assessment
Under current EPA guidelines, the likelihood of adverse effects to
occur in humans from carcinogens and noncarcinogens are considered
separately. Cancer slope factors have been developed by EPA for
estimating excess lifetime cancer risks asscociated with exposure
to potentially carcinogenic chemicals. Slope factors, which are
expressed in units of (kg-day/mg), are multiplied by the estimated
intake of a potential carcinogen, in mg /kg-day, to provide an
upperbound estimate of the excess lifetime cancer risk associated
with.exposure at that intake level. The term "upperbound" reflects
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November 1994
FCX-STATESVILLE OU2
PAGE 14
the conservative estimate of the risks calculated from the slope
factor. Use of this approach makes underestimation of the actual
cancer risk highly unlikely. Cancer potency factors are derived
from the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applieq.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals that are likely to be
without risk of adverse effect. Estimated intakes of chemicals
from environmental media can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied. These uncertainty
factors help ensure that the RfDs will not underestimate the
potential for adverse no_ncarcinogenic effects to occur.
D. Risk Characterization
The risk characterization step of the risk assessment process
integrates the toxicity and exposure assessments into quantitative
and qualitative expressions of risk. The output of this process is
a characterization of the Site-related, potential carcinogenic and
noncarcinogenic health effects.
Carcinogenic risk is calculated using the following equation: Risk
= CDI X SF, where CDI = chronic daily intake averaged over 70 years
(mg/kg/day), and SF = slope factor expressed as ·(mg/kg/day)-1 •
Carcinogenic risk is expressed as the incremental probability of an
individual developing cancer over a lifetime as a result of
exposure to one or more cancer-causing substances. These
probabilities are generally expressed in scientific notation (e.g.,
1x10-• or lE-6 ) • An excess lifetime cancer risk of 1 X 10-•
indicates that, as a reasonable maximum estimate, an individual has
a 1 in 1,000,000 chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at a site.
EPA has developed guidelines for carcinogen risk characterization.
These guidelines discuss weighing the evidence that a substance is
a carcin.ogen and classifying the suspect chemical into one of the
five groups:
*
*
*
*
*
Group A -Human Carcinogen
Group B -Probable Human Carcinogen
Group C -Possible Human Carcinogen
Group D -Not Classified as a Human Carcinogen
Group E -Evidence of Noncarcinogeneity for Humans
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November 1994
FCX-STATESVILLE OU2
PAGE 15
The potcential risk for noncarcinogens, better known as the hazard
quotient or HQ, is presented as the ratio of the CDI to the
reference dose (RfD) for each chemical. A hazard index or HI is
the sum of the HQs for a particular exposure pathway, or the sum of
the HQs across multiple exposure pathways for an individual
receptor. The HI is useful as a reference point for gauging if the
potential exists for adverse health effects to occur from a
particular exposure pathway ( s) . When the calculated HI exceeds 1. 0
for multiple contaminants or multiple exposure pathways, there may
be concern for potential adverse health effects.
Table 1 shows the model used for calculating doses from the dermal
contact of contaminated surface soil, including the exposure
assumptions associated with the surface soil at the Site. Table 2
shows the model used for calculating doses from the incidental
ingestion of contaminatE!d surface soil, including the exposure
assumptions associated with the surface soil at the Site. Table 3
shows the exposure point concentrations for the chemicals of
concern for the Site. Table 4 summarizes the carcinogenic and
noncarcinogenic toxicity criteria for the Site-related contaminants
of concern in the soil.
Current Land Use
For current residents living in close proximity to the Site, no
carcinogenic or noncarcinogenic risks were identified at levels
,greater than lE-4 (l-in-10,000) or with an HI greater than 1.0.
This means that the probability of a current resident (child or
adult) having adverse "health effects from dermal contact or
ingestion of cancer-causing contamination in the soil in areas 1,
2, or 3 is less than one-in-ten-thousand (lE-4).
Future Land Use
For future residents living on-site in areas 1 and 2, carcinogenic
risks were identified for both child and adult residents at levels
which were equal to or in excess of lE-4. Hazard Index values for
noncarcinogenic contaminants were also identified for the future
resident (both child aged 1-6 and adult) in excess of 1.0. These
risk values mean that the probability of a future resident having
adverse health effects from cancer-causing contamination at the
Site is greater than !-in-ten-thousand. The next two paragraphs
summarize the risks to future residents living on the Site.
The total carcinogenic risk for the future child and adult resident
from thed."ermal contact and ingestion of contaminated surface soil
was 4E-4 (4-in-10,000). A 4E-4 risk level exceeds the risk range
from lE-4 to lE-6, which EPA-Region IV considers to be acceptable
for most hazardous waste sites. The carcinogenic risk for the
child resident aged 1-6 from dermal contact and ingestion of
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 16
contaminated surface soil was 2E-4 (2-in-10, 000). The carcinogenic
risk for the child resident aged 7-12 from dermal contact and
ingestion of contaminated surface soil was lE-4. The carcinogenic
risk for the adult resident from dermal contact and ingestion of
contaminated surface soil was lE-4.
The carcinogenic risk for the future on-site worker (assuming the
existing buildings remain) from the dermal contact or ingestion of
contaminated surface soil at the Site was lE-5 (1-in-100,000).
The carcinogenic risk for the on-site worker (assuming the
buildings are removed) from the dermal contact and ingestion of
contaminated surface soil at the Site was 4E-5 (4-in-100,000).
In evaluating potential risks to future on-site workers working
within the existing warehouses, air monitoring was conducted in
three locations within the warehouses during two consecutive 24-
hour periods. The results were evaluated against the Occupational
Safety and Health Administration (OSHA) established limits. These
federal limits are referred to as permissible exposure limits
(PELs) determined with the time weighted average (40 hr/week, 8
hr/day scenario), which are referenced criteria for any EPA
remedial activity. None of the air/ sample data collected and
analyzed from the Site exceeded the PELs.
The total noncarcinogenic risk for the future child and adult
resident living on-site (assuming the existing buildings are
_.removed) was 3. 6. The noncarcinogenic risk for the future child
resident aged 1-6 from the dermal contact and ingestion of
contaminated soil was 1.4. The noncarcinogenic risk for the future
child resident aged 7-12 from the dermal contact and ingestion of
contaminated surface soil was 5.3. The noncarcinogenic risk for
the future resident living on-site from dermal contact and
ingestion of contaminated surface soil was 1.4. Table 5 shows the
carcinogenic and non-carcinogenic risk levels for the exposure
pathways evaluated.
E. Environmental (Ecological) Assessment
Potential risks to environmental receptors at or near the Site were
evaluated based on Site sampling data and a review of the toxicity
of the chemicals of potential concern to ecological receptors. Use
of the Site by terrestrial receptors such as birds and small
mammals, particularly the area presently covered by the brick
warehouses and paved parking lot, was considered unlikely given the
lack oLl_rees or other vegetative cover at the Site.
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TABLE 1
Model f9r Calculating Doses from
Dermal Contact with Soil
Dermal Absorption Dose CS x CF x SA X AF
(mg/kg-day) = BW x·
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 17
x ABS x EF x ED
AT
Where:
cs = Chemical concentration in soil (mg/kg)
CF = Conversion factor (10-6 kg/mg)
SA = Skin surface area available for contact (cm2 /day)
AF = Soil to skin adherence factor (mg/cm2 )
ABS = Dermal absorption factor (unitless)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days)
Assumptions:
i cs = Upper 95% confidence limit /of the mean concentration
in soil.
SA = 2,125 cm2 /day for the child (1-6) resident. It
represents tlie 50th percentile surface area of the
arms, hands, lower legs, and feet (50% of the
exposure events) and forearms and hands (50% of the
exposure events) of a 1-6 year old (Anderson, 1985).
= 4,453 cm2 /day for the child (7-12) . It represents
the 50th percentile surface area of the arms, hands,
lower legs, and feet (100% of the exposure events)
(Anderson, 1985).
= 4,145 cm2 /day for the adult resident. It represents
the 50th percentile surface area of the arms, hands,
lower legs, and feet (50% of the exposure events) and
forearms and hands (50% of the exposure events) of an
adult male (EPA, 1992).
= 1,980 cm2 /day for the future worker. It represents
the 50th percentile surface area of the forearms and
hands of an adult male (EPA, 1992) .
AF = 1 mg/cm2 , soil adherence factor (EPA, 1992b).
ABS = 0.01 -Organic compounds (EPA, 1992a) -0.001 -Inorganic compounds (EPA, 1992a).
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TABLE 1 (Continued)
Model for Calculating Doses from
Dermal Contact with Soil
Dermal Absorption Dose CS x CF x SA x AF
(mg/kg-day) = BW x
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 18
x ABS x EF x ED
AT
Where:
cs = Chemical concentration in soil (mg/kg)
CF = Conversion factor (10'6 kg/mg)
SA = Skin surface area available for contact ( cm2 /day)
AF = Soil to skin .adherence factor (mg/cm2 )
ABS = Dermal absorption factor (unitless)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days) '
EF = 45 days/year for trespasser (approximately once a
week). i I 320 days/year for child (7,12) trespasser/resident.
350 days/year for the child and adult residents (EPA,
1991a) .
250 days/year for the future worker (EPA, 1991a) .
ED = 6 years for the child (1-6) resident (EPA, 1991a).
6 years for the current child (7-12)
trespasser/resident (EPA, 1991a).
25 years for the on-site worker (EPA, 1991a) .
= 18 years for the adult resident (EPA, . 1991a) .
BW = 15 kg for the child resident (EPA, 1991a).
27 kg for the current child (7-12)
trespassers/resident (EPA, 1991a)
70 kg for the adult resident (EPA, 1991a).
70 kg for the future worker (EPA, 1991a).
AT = Exposure duration (years) X 365 days/year for
evaluating noncancer risk.
= 70 years X 365 days/year for evaluating cancer risk.
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Where:
cs =
IR =
CF =
EF =
ED =
BW =
AT =
TABLE 2
Model for Calculating Doses from
Incidental Ingestion of Soil
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 19
Soil Ingestion Dose CSX IR x CF x EF x ED
(mg/kg-day) = BW x AT
Chemical concentration in soil (mg/kg)
Soil ingestion rate (mg/day)
Conversion factor (10-6 kg/mg)
Exposure frequency (days/year)
Exposure duration (years)
Body weight (kg)
Averaging time (days)
Assumptions:
cs = Upper 95% confidence limit of the mean concentration
in soil. I
IR = 200 mg/day for the child (1-6) resident (EPA, 1991a).
100 mg/day far the child (7-12) (EPA, 1991a).
100 mg/day for the adult resident (EPA, 1991a) .
50 mg/day for the future worker (EPA, 1991a) .
EF = 45 days/year for trespasser (EPA, 1991a)
320 days/year for the Child (7-12) offsite resident
(EPA, 1991a)
350 days/year for the children and adult residents
(EPA, 1991a).
250 days/year for the future worker (EPA, 1991a) .
ED = 6 years for the child (1-6) resident (EPA, 1991a).
6 years for the current child ( 7 -12) (EPA, 1991a).
18 years for the adult resident (EPA, 1991a).
= 25 years for the future on-site worker (EPA, 1991a).
BW = 15 kg for the child resident (EPA, 1991a) .
27 kg for the current child (7-12) trespassers (EPA,
1995)
70 kg for the adult resident (EPA, 1991a) .
70 kg for the future worker (EPA, 1991a) .
AT = Exposure duration (years) x 365 days/year for -evaluating noncancer risk.
= 70 years x 36-5 days/year for evaluating cancer risk.
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CHEMICAL OF
CONCERN
ARSENIC
BERYLLIUM
BENZO(A)PYRENE
DIBENZO(A,H)-
ANTHRACENE
BENZO(B,K)-
FLUORANTHENE
PENTACHLORO-
PHENOL
DIOXIN (TEQ)
TABLE 3
EXPOSURE POINT CONCENTRATIONS
FOR CHEMICALS OF CONCERN (MG/KG)
EXPOSURE POINT CONCENTRATIONS
AREA 1 AREA 2
2.7 6.6
0.7 0.7
0.8 1. 2
0.6 0.5
1·.1 I 2.4
----------
.000026 .000045
(-----) -None Detected
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 20
(MG/KG)
AREA 3
-----
-----
0.5
-----
0.6
34
.00071
--· .. .a.,.--... ------ -
Oral Slope Dermal Slope
Factor factor
(mg/kg/day)"'
Arsenic l.75E+OO 8.75
Beryllium 4.30E+OO 2.15E+0l
Benzo(B and/or K)Fluoranthene 7.3E+OO l.46E+l
Benzo-A-Pyrene 7,JE+OO l.46E+l
Dibenzo(A.ll)Anthracene 7.3E+OO l_.46E+l
Pentachlorophenol l.20E-0l 2.4E-l
-- --
TABLE 4
TOXICITY VALUES FOR
CHEMICALS OF CONCERN
Ref. Oral RID Dennal
(mg/kg/day) RID
IRIS, 3.00E-04 6E-5
1992
IRIS, 5.00E-03 IE-3
1992
N1V
IRIS, N1V. ---1992
N1V
IRIS, 3.00E-02 l.5E-2
1992
1Convcrted from a unit risk assuming the ingestioo. of 2 liters of drinking water per day and a body weight of 70kg (EPA, 1992)
NTV = No Toxicity Value
Dermal RfDs/SFs are derived
Absorption Factors (ABS): 0.2 -In.organics, 0.8 -Volatile Organics, 0.5 -Semi-volatile Organics/Pesticides/PCBs
Dermal RID = Oral RID x ABS
Denna! Slope Factor= Oral SF/ABS
-- -
Ref. Inhalation Slope
F~ctor (mpkglday)
IRIS, l.S0E+0l
1992
IRIS, 8.40E+00'
1992
N1V
NlV
N1V
IRIS, N1V
1992
-
Ref.
IRIS,
1992
IRIS,
1992
- - -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 21
/.
Inhalatloo Rm Ref.
(mg/kg/day)
N1V
N1V
N1V
N1V
N1V
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LAND USE
CURRENT
FUTURE
TABLE 5
CARCINOGENIC AND NON-CARCINOGENIC RISK
LEVELS FOR CHEMICALS OF CONCERN
EXPOSURE PATHWAY CARCINOGENIC
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 22
NON-
RISK CARCINOGENIC
RISK
(HI)
CHILD AGED 1-6 3xlo-s 0.5
CHILD AGED 7-12 lx10-5 0.1
ADULT lx10-5 0.1
CHILD AGED 1-6 2x10-' 1.4
CHILD AGED 7-12 lxlo-' 0.5
ADULT I lxlo-' 1. 4
Based on a qualitative analysis, terrestrial wildlife communities
in the low-lying and wooded areas near the Site are not likely to
be significantly impacted. In order to evaluate the potential
--risks to aquatic receptors at the Site, the surface water
concentrations were compared with North Carolina Surface Water
Quality Standards and Ambient Water Quality Criteria used by EPA-
Region IV as chronic screening values. Several pesticides were
identified in the surface water and sediment at sample location FS-
020, located south of Front Street along an unnamed branch of Free
Nancy Creek. Pesticide concentrations at this one sample location
exceeded both the State Standards and chronic screening values for
surface water. Therefore, the potential exists for adverse effects
to aquatic biota at sample location FS-020 due to surface water
contamination. The National Oceanic and Atmospheric
Administration's (NOAA) Effects Range concentrations were also used
by EPA-Region IV as sediment screening values. Pesticide
concentrations in the sediment at sample location FS-020 exceeded
the NOAA Effects Range concentrations; therefore, the potential
exists for adverse effects on aquatic biota at sample location FS-
020 due to sediment contamination.
Due to tr:-fle isolated nature of the pesticide contamination at sample
location FS-020, EPA does not believe that a response action is
warranted for surface water and sediment. However, several
volatile organic compounds were identified in surface water and
sediment samples collected around the Site during the Phase I
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FCX-STATESVILLE OU2
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Remedial,. Investigation. Due to the presence of the volatile
organic compounds in the surface water and sediment, additional
sampling of the surface water pathways around the Site is currently
underway as part of the Operable Unit Three Remedial Investigation
to determine if remedial action is warranted.
VII. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Section 121 (D) of CERCLA, as amended by SARA, requires that
remedial actions comply.with requirements or standards set forth
under Federal and State environmental laws. The applicable or
relevant and appropriate requirements (ARARs) that must be complied
with are those that are (A) action-specific, (B) location-specific,
or (C) chemical-specific at the Site.
ARARs are used to determine the appropriate extent of Site cleanup,
to scope and formulate remedial action alternatives, and to govern
the implementation and operation of the selected action. "To be
considered" materials (TBCs) are non-promulgated, non-enforceable
advisories, guidelines, ·or criteria issued by federal or state
governments (e.g., reference doses .and carcinogenic potency
factors) that may be useful for developing remedial action
alternatives or for determining what is protective to human health
and the environment. This section examines the cleanup criteria
associated with the contaminants identified during the RI/FS and
the environmental media contaminated.
A. Action-Specific ARARs
Action-specific requirements set controls or restrictions on the
design, performance, and other aspects of implementation of
specific remedial activities. A retained alternative must conform
with all ARARs unless a statutory waiver is invoked.
B. Location-Specific ARARs
Location-specific ARARs
restrictions based on the
Site and its surrounding
are design requirements or activity
geographical or physical positions of the
area.
C. Chemical-Specific ARARs
Chemical-specific ARARs include those laws and regulations
governing the release of materials possessing certain chemical or
physical characteristics, or containing specified chemical
compounds: These requirements generally set health or risk-based
concentration limits or discharge limitations in various
environmental media for specific hazardous substances,
contaminants, and pollutants.
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VIII. REMEDIAL ACTION OBJECTIVES
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 24
The Remedial Investigation and Baseline Risk Assessment indicate
that elevated levels of the Site-related contaminants DDT, DDD;
gamma-BHC (lindane), endrin, dieldrin, chlordane, and penta-
chlorophenol are present in the soil at the Site. The Operable
Unit Two Remedial Action will address this pesticide contamination
by: 1) reducing levels of pentachlorophenol in the surface soil
( top one foot) to 3. 2 parts per million based on the 10-6 risk level
for dermal contact and ingestion, and 2) to reduce the amount of
total pesticides in the surface and subsurface soil to one parts
per million as a source of groundwater contamination.
Elevated levels of arsenic, beryllium, benzo(a)pyrene,
dibenzo(a,h)anthracene, and benzo(b,k)fluoranthene were identified
in the soil at the Site; however, EPA does not believe that these
chemicals are associated with former FCX operations. Dioxin was
also identified in the soil at levels below EPA's normal
remediation level of one part per billion (ppb). Therefore, EPA
does not plan to remediate these chemicals.
EPA has established the remediation le1el for pentachlorophenol in
the surface soil based on the 10-6 risk level. EPA has established
a cleanup level for total pesticides in the surface and subsurface
soil based on the following rationale. Pesticide application has
been a widespread activity for a number of years because North
.. Carolina is a heavily agricultural state. Normal agricultural
pesticide usage has resulted in observed background pesticide
levels in the one part per million (ppm) range.
These field observations are also supported by suggested
application rates. For example, the Water Resources and Research
Institute (WRRI), Report No. 60, "Contamination of Surface and
Ground Water with Pesticides Applied to Cotton" indicates that in
1972 the standard application rate for DDT and methyl parathion was
1 lb/acre and for toxaphene was 2 lbs/acre. These applications
were made twelve ( 12) times per growing season. Assuming an
application rate of 2 lbs/acre and a till depth of 6 inches (and
uniform mixing) this would result in a concentration of 1 ppm (soil
density of 4,000,000 lbs. weight for one acre of soil one ft. deep
was also assumed). Considering this and the fact that, for this
Site, any direct contact to soil at this level is well within EPA's
acceptable risk range, a·total pesticides concentration of one ppm
is being used as a performance standard for this ROD.
EPA acknowledges that an estimated 1. 6 percent of the total
pesticides in the surface and subsurface soil at the Site are not
targeted for excavation, and may leach into the groundwater at
levels above the remediation levels established in the Operable
Unit One Record of Decision. For this reason, EPA and the State
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 25
believe-0.it is important to install a groundwater pump-and-treat
system, as well as continue monitoring the groundwater as part of
the Operable Unit One Remedial Action.
IX. DESCRIPTION OF ALTERNATIVES
The six remedial
contamination on the
brief summary.
alternatives developed to address soil
FCX property are shown listed below with a
Alternative 1: No Action
Alternative
restrictions
warehouses.
2: Limited Action
and limited paving
includes property
of areas around
deed
the
Alternative 3: Demolition of buildings and paving of all areas
with soil contamination. Property deed restrictions would be
imposed.
Alternative
excavated,
Desorption
backfilled
4: Demolition of builhings, contaminated
stockpiled, and treated on-site using
and Base Catalyzed Decomposition. Treated
on-site.
Alternative 5: Demolition of buildings, contaminated
excavated, stockpiled, and treated on-site using
Desorption and alternate method of treating off gases.
soil is backfilled ·on-site.
soil is
Thermal
soil is
soil is
Thermal
Treated
Alternative 6: Demolition of buildings, contaminated soil is
excavated, stockpiled, and transported off-site for treatment
at an approved RCRA incineration facility. Clean soil would
be brought to the site to replace excavated soil.
An analysis of the potential Federal action-, location-, and
chemical-specific ARARs is provided in Table 6. An analysis of the
potential State action-, location-, and chemical-specific ARARs is
provided in Table 7.
--- - - ---- - -
TABLE 6
Analysis of Federal ARARs
Standard, Requirement, Regulatory
Criteria, or Limitation Citation Description
Resource Conservation and Recovery Act
Chemical-Specific ARARs
Identification and Listing of 40 CFR Part 261 Defines those solid wastes which are subject to
Hazardous Waste regulation as hazardous waste under 40 CFR
Parts 262-270.
Resource Conservation and Recovery Act (continued) -
Action-Specific ARARs
Requirements for hazardous 40 CFR Part 262 Establishes standards for generators of hazardous
waste generators Subparts A,B,C,D wastes.
Requirements for transporters of 40 CFR Part 263 Establishes standards which apply to transporters
hazardous waste Subparts A,B,C of hazardous waste within the United States if
the transportation requires a manifest under 40
CFR Part 262.
- - -- -
FINAL ROD
November 1994
FCX-STATESVILLE 002
PAGE 26
Justification
Comments
Applicable to remedial actions
involving solid waste (soil) removal in
the identification of wastes and
application of other action specific
ARARs.
Applicable to remedial actions
involving removal of hazardous waste.
Applicable to remedial actions
involving removal of hazardous waste.
-
-- -
Standard, Requirement,
Criteria, or Limitation
Requirements for hazardous
waste treatment, storage, and
disposal (TSD) facilities.
.. ;
Land Disposal Restrictions
Clean Water Act (CWA)
Chemical-Specific ARARs
I Water quality criteria
':f---
Action-Specific ARARs
- --- --- -
Regulatory
Citation
40 CFR Part 264
Subpart L.. .......
Subpart M .........
Subpart N .........
Subpart X .........
40 CFR Part 268
CWA Part 303
40 CFR Part 13 I
TABLE 6 (Continued)
Analysis of Federal ARARs
Description
Regulates owners and operators of facilities that
store or treat hazardous waste in piles. ·
Regulates owners and operators of facilities that
treat or dispose of hazardous waste in land
treatment units.
Regulates owners and operators of facilities that
dispose of hazardous· w~e in landfills.
Regulates owners and operators of facilities that
treat, store, or dispose of hazardous waste in
miscellaneous units.
Identifies hazardous wastes that are restricted
from land disposal
Establishes water quality criteria based on the
protection of human health and aquatic life.
-- -- -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 27
Justification
Comments
Applicable to remedial activities
requiring the formation of waste piles.
Applicable to remedial activities
requiring the formation of land
treatment units.
Applicable io remedial activities
requiring the disposal of hazardous
waste in landfills .
. Applicable to remedial activities
requiring thermal treatment of
hazardous waste in a miscellaneous
unit.
Applicable to remedial actions
involving removal of hazardous wastes
(e.g., soil excavation)
Applicable to remedial actions
involving discharge of water to a
surface water body.
-
----- - - - --- --('
' ',,..:__ -~ -.r
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
National Pollutant Discharge CWA Part 402
Elimination System (NPDES) 40 CFR Part 125
requirements
National pretreatment standard CWA Part 307(b)
for indirect discharge to a 40 CFR Part 403
POTW
Technology-based effluent CWA Part 30l(b)
limitations
Safe Drinking Water Act (SDW A)
Chemical-Specific ARARs
National Primary Drinking 40 CFR Part 141
Water Standards
National Secondary Drinking 40 CFR Part 143
Water Standards
Clean Air Act (CAA)
Chemical-Specific ARARs
.--...
TABLE 6 (Continued)
Analysis of Federal ARARs
Description
Requires permit for effluent discharge from any
point source into surface waters of the United
States.
Establishes standards to control pollutants which
pass through or interfere with treatment processes
in public treatment worl<s which may
contaminate sewage sludge.
Establishes guidelines to determine effluent
standards based on the best available technology
(BAT) economically .achievable. ---
Establishes health-based enforceable standards
for public water systems (maximum contaminant
levels (MCLs)).
Es~lishes aesthetic-based, non-enforceable
guidelines for public water systems (secondary maximum contaminant levels (SMCLs)).
- - - - -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 28
Justification
Comments
Applicable to remedial actions
I :·
involving discharges to surface waters.
Applicable to discharge of water into
local POTW.
Applicable to aqueous effluent from
remedial processes.
Applicable to remedial actions
involving in-place treatment of soils,
Applicable to remedial actions
involving in-place treatment of soils.
-
-- - - - - - - --- --- - -
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
National Ambient Air Quality 40 CFR Pan 50
Standards (NAAQS)
National Emission Standards for 40 CFR Pan 61
Hazardous Air Pollutants
(NESHAP)
Occupational Safety and Health Act
Action-Specific ARARs
Safety of workers 29 USC 651-678
29 CFR 1910
Hazardous Materials Transportation Act
Action-Specific ARARs
Hazardous Materials 49 USC 1801-1813
Transportation Regulations 49 CFR 107, 171-
177
Protection of Wetlands (Executive Order 11990)
Location-Specific ARARs
TABLE 6 (Continued)
Analysis of Federal ARARs
Description
Establishes ambient air quality standards for
classes of pollutants -carbon monoxide,
hydrocarbons, lead, nitrogen dioxide, paniculate
matter, ozone, and sulfur oxides. Standards do
not apply' directly to source-specific emissions,
but are ambient concentration limitations.
Establishes emission standards for seven
contaminants • benzene, mercury, arsenic,
asbestos, beryllium, vinyl chloride, and
radionuclides.
--
Regulates workers' health and safety.
Regulates transportation of Department to
Transportation {DOT)-defined hazardous
materials.
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 29
/,
Justification
Comments
Only "major sources" (emissions
exceeding 100-250 tons per year of
regulated pollutants) are subject to
NAAQS attainment requirements.
Not applicable to the site as benzene
and vinyl chloride are not produced as
a result of manufacturing operations.
Applicable to remedial actions at the
site.
Applicable to remedial action involving
transportation of DOT -<lefined
hazardous materials off-site.
-
- - --------- - - -- -- - -r
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Historic, prehistoric and Archeological
archeological data Preservation Act of
1974, 16 USC 469
et seq.
Executive Order
11593
40 CFR 6.30l(c)
Endangered Species Act
Action-Specific ARARs
Protection of endangered 16 USC 1531
species 50 CFR Part 200
50 CFR Part 402
Fish and Wildlife Coordination Act
Action-Specific ARARs
Protection of fish and wildlife 16 USC 661-666
due to any modifications of
water bodies.
TABLE 6 (Continued)
Analysis of Federal ARARs
Description
Establishes regulations to protect historic,
prehistoric, and archeological data during
remedial actions.
Requires action to consen-e endangered species
and/or critical habitats upon which endangered
species depend.
Requires adequate provision for protection of fish
and wildlife resources when any modification of
any stream or other water body is proposed.
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 31
/.
Justification
Comments
Site is not located in an area with
prehistoric or archeological data.
Potentially applicable as endangered
and threatened species have been
identified as candidate species in Iredell
Onslow County.
Potentially applicable if the remedial
action involves discharge of treated
water to New River.
--- - - - --
TABLE 7
---- -- -ff~ .. ,. !
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 32
! '
Analysis of State of North Carolina ARARs
Standard, Requirement, -Justification
Criteria, or Limitation Citation Description Comments
North Carolina Waste Management Rules and Solid Waste Management Law
Chemical-Specific ARARs
Identification and listing of ~ANCAC Defines those solid wastes which are subject to Potentially applicable to remedial
hazardous waste. 13 A (.0006-.0014) state regulation and as a hazardous waste. actions involving solid waste (soil)
Consistent with corresponding federal standards removal. -
( characteristic and listed hazardous waste
•designations).
North Carolina Water and Air Resources Act
Action-Specific ARARs --
Laws to achieve and to General Statutes, State equivalent of the Federal CW A and CAA Potentially applicable for remedial
maintain a total environment Chapter 14 3 Article action involving discharge of water and
with superior quality. 2IB air emissions.
North Carolina Drinking Water Act
Action-Specific ARARs
Regulations on drinking water General Statut.:s Establishes criteria for protci:tion of state public Potentially applicable to remedial
Chapter 130A, water supplies. actions involving in-place treatment of
Article 10 soils,
-
-- - -- - -('
\ - - -
TABLE 7 (Continued)
- - - -
FINAL ROD
Novembei-1994
FCX-STATESVILLE OU2
PAGE 33
Analysis of State of North Carolina ARARs
Standard, Requirement, Justification
Criteria, or Limitation Citation Description Comments
Nonh Carolina Solid Waste NCAC Title 15A, Provides design, operation, and closure Potentially applicable to remedial
Disposal Regulations Chapter 13B . requirements for solid waste -disposal facilities actions involving point source
discharges to surface waters.
NCAC Title 15A,
Chapter 2
Nonh Carolina Air Pollution Subchapter 2D ..... Regulates air pollution, air quality, and emissions
Control Requirements standards
Subchapter 2H. .... Requires permit for discharge of effluent from
point sources into surface waters. State-level
version of federal NPDES program.
Nonh Carolina Provides requirements for the prevention of
Sedimentation Control NCAC Title 15A, _sedimentation pollution.
Rules Chapter 4 .........
North Carolina Drinking Water and Groundwater Standards
Chemical-Specific ARARs
Groundwater Classifications and NCAC Title 15A, Establishes groundwater and drinking water Potentially applicable to remedial
Standards Chapter 2, standards based on the usage. actions involving in-place treatment of
Subchapters soils.
2L.0100, 2L.0200,
and 0.0201
.
-
------ - -- - -
TABLE 7 (Continued)
-- - - -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 34
I !·
Analysis of State of North Carolina ARARs
.
Standard, Requirement, Justification
Criteria, or Limitation Citation Description Comments
North Carolina Surface Water Quality Standards
Chemical-Specific ARARs
Classification and water quality NCAC Title 15A, Establishes a series of classifications and water Potentially applicable to discharge of
standards applicable to surface Chapter 2, quality standards for surface waters. water to a surface water body.
water. Subchapters 2L.0100
and 2L.0200
Technology-based effluent NCAC Title 15A, Establishes guidelines for effluent limitations Potentially applicable to discharge of
limitations Subchapter 2B.0400 based on BAT ecm1omically achievable. water. --
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 35
Each of~the six alternatives is briefly described below. Table 8
shows the soil remediation levels for the Site-related chemicals of
concern. The estimated total extent of pesticide soil
contamination is shown on Figure 5. The vertical extent of the
soil contamination ranges from the ground surface to depths of 7 to
10 feet below land surface. Table 9 also shows how the six
alternatives either meet or do not meet the nine evaluation criteria.
Alternative 1: No Action
By law, EPA is required to evaluate a No Action Alternative to
serve as a basis'against which other alternatives can be compared.
No remedial action of the contaminated soil would take place under
the No Action Alternative. Therefore, the existing structures
(i.e., buildings•and parking areas) would remain intact. There are
no capital costs associated with Alternative 1. However, five-year
reviews of the remedy would be conducted for an estimated period of
30 years to determine if the No Action alternative remained
protective of human health and the environment. The estimated
present worth cost for the five-year reviews is $55,640.
Capital Costs
Present Worth O & M Costs
Total Present Worth Costs
Alternative 2: Limited Action
$ 0
$.1 55, 640
$ 55,640
As with the No Action Alternative, no remediation of the
. contaminated soil would · take· place under the Limited Action
Alternative. The Limited Action Alternative would not reduce
contaminants in the surface soil to levels that are considered
protective of human health and the environment.
TABLE 8
Soil Remediation Levels
Remedial Goal (mg/kg)
Total Pesticides• 1.0
Pentachlorophenplb 3.2
•Defined as gamma-BHC (Lindane), endrin, dieldrin, chlordane, DDT, and DDD.
bApplies only to the top one foot of soil.
The !"xi sting stru.ctures (i.e., buildings and paved areas) would
remain intact. However, the areas of contaminated soil not
presently covered by a warehouse or a paved surface would be
capped. Additional capping or paving of those contaminated areas
would reduce the possibility of future residents or on-site workers
\
---I""""· --B, -X I X I X I RESIDENTIAL AREA TOT.ot. AAf:A: :S1480 SQ. n. 0 150 -300 I ------1 SCALE FEET FIGURE 5 -Areas of contaminated Soil to be Remediated ---BURLINGTON INDUSTRIES DRA'w'N 0.0. CHECICCD --Ii 19i IATE APPRCVED ---SOURCE: !PA 91[ II.AT> OH1EIJ.4l DATE ,.-.1[ "'· a. NO. 04400-01-0~ DVG. Nil - -!, .-·--,, "' n " ' u, ;l z 80 '"< u, 0 ;S 6-~ 'tl t"' t'D z ~fu'"I ~ '" ~ o~:o WCl.00 O'\N.,,..0 -
- - -
Alternative 1
Criteria No Action
Overall Protectmn of Does not rmllgate-
Human Health and the risks or achieve
Environment remediation goals.
Compliance with ARARs
• Chemical-Specific Does not meet.
(Cleanup Goals)
• Action-Specific NIA
• Location-Specific NIA
--- -- - - - --
TABLE 9
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4 Alternative 5
-
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Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD Thermal Desorption
Would limll direct Higher degree of Eliminates the nsk of Same as Altemallve
exposure and protection against exposure to soil 4.
protect human exposure than contaminants by
health. Meets Alternative 2. Meets human receptors.
criterion. criterion. Exceeds criterion.
NIA NIA Expected to meet Expected to meet
N/A NIA. Requires special Same as Altemallve --handling, storage, 4.
treallnent, and dis-
posal of hazardous
waste
NIA NIA NIA NIA
----
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 37
!-
Alternattve 6
Off-Site Incineration
Same as Alternative 4.
Expected to meet
Must meet RCRA
land disposal
restrictions and DOT
manifesting
procedures.
NIA
-- -- - -r-\ . '
Alternative 1
-
Criteria No Action
Short-Tenn Effectiveness
• rrotectIOn ot !~/A
Community Iluring
· Implementation
• Protecuon of NIA
Workers
• tmvrronmemai 1~/A
Impact
Long-Tenn Quesuonable
Effectiveness whether soil
remediation goals
can be met through
natural degradation.
Five-year review
required.
Roouclion ot 'loxic1ty, MOOlllty, and volume
• Treatment Process None
Used and Materials
Treated
-- -- ---
TABLE 9 {Continued)
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4
--
Thennal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
!~/A Dust control Controls requtre0 to
measures would be protect against dust
required during generation during
building demolition. excavation and
building demolition.
No significant risk Physical hazards Protection required
to workers. associated with against dennal
---
Alternative 5
Thennal Desorption
Controls requtreo to
protect against dust
generation during
excavation and
building demolition.
Protection required
against dennal
building demolition. contact and inhalation contact and inhalation
of contaminated dust of contaminated dust
during excavation, during excavation,
demolition, and demolition, and .
treatment treatment
Mimmat Minunat
Reduces continued Sarne as Alternative Provides pennanent Sarne as Alternal!ve
infiltration and 2. and effective means 4.
leaching of of eliminating source
contaminants into for groundwater
groundwater. contamination.
Eliminates direct
contact risks. Five-
year review
required.
None None Achieves treatment Achieves treatment
- - -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 38
! ,.
Alternative b
Off-Site Incineration
Controls requtreo to
protect against dust
generation from
excavation, building
demolition, and truck
traffic.
Protection required
against dennal
contact and inhalation
of contaminated dust
during excavation,
demolition, and
trucking.
Nlm11Ilal
Sarne as Alternal!ve 4.
Achieves treatment
-- -- - -
Alternative 1
Criteria No Action
• Amount of None
Hazardous
Materials
Destroyed or
Treated
• Degree 01 expecieu Does not meet
reduction in CERCLA
toxicity, mobility, preference for
and volume. treatment remedies.
• Degree of NIA
Irreversibility
• Type and quanllty NIA
of residuals
remaining.
Implementability
• Ability to N/A.
Construct and
Operate the
Technology.
• Ease of Site NIA
Preparation
- ---- - -
TABLE 9 (Continued)
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4
. ---. ---
Thennal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
None None 6,945 cubic yards of
contaminated soil
treated.
Does not meet Does not meet Rroucuon 01 soll
CERCLA CERCLA preference contamination below
preference for for treatment soil remediation
treatment remedies. remedies. goals.
Cap and buildings Cap could be • . --Process would be
could be removed. removed. irreversible.
NIA NIA Residual soil
contamination below
remediation goals
- --
Alternative 5
Thennal Desorption
b,945 cubic yards 01
contaminated soil
treated.
Reducuon ol SOIi
contamination below
soil remediation
goals.
Process would be
irreversible.
Same as Alternative
4.
would be delisted and
backfilled.
Road pavmg Road pavmg M0Dlle umt Moone umts are
equipment easily equipment operated commercially available to handle
operated. easily. Building available to handle the expected soil
demolition requires the expected soil volumes. Demolition
additional planning volumes. Demolition and excavation
but easily perfonned. and excavation implementable.
implementable.
Only minor grading Would require Would require Same as Alternative
required. decontamination and warehouse demolition 4.
demolition of and decontamination -buildings. facilities.
- - -:/i; ..... \
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 39
I ;'
Alternative 6
. -
Off-Site Incineration
b,945 cubic yards of
contaminated soil
destroyed.
Ureater man .,.,_.,,.,,o
destruction of organic
contaminants through
incineration.
Process would be
irreversible.
Ash residual disposed
of by incineration
facility.
Penn1treo mcmerators
are available with the
capacity to handle the
expected soil volumes.
Demolition and
excavation
implementable.
Same as Alternative 4.
- --
Alternative l --
Criteria No Action
• Ease of N/A
Undertaking
Additional
. Remedial Actions
• Ability to Monitor N/A
Effectiveness
• Ability to Obtam N/A
Approval from
Other Agencies
• Availability of N/A
Materials ·
• Availability of NIA
Unusual or Special
Services
Esumated Cost (1994 $)
• Capital Cost 0
• Annual O&M Cost
(Years 1-30) $20,000 *
• Present Worth ** $ 55,640
* Review performed every 5 years.
-- - -- - -
TABLE 9 (Continued)
Evaluation of Remedial Alternatives
Alternative 2 . Alternative 3 Alternative 'I
Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
Would not mterfere Would not mterfere Would not interfere
with any future with any future with any future
actions. actions. actions.
Pavement would be Same as Alternative Confinnation soil
inspected for 2. sampling easily
cracks. performed.
N/A N/A Community may
express concern over --thermal treaunent on-
site.
-- -
Alternative S
-
Thermal Desorption
Would not interfere
with any future
actions.
Same as AlternaUve
4.
Same as Alternative
3.
All materials All materials All materials obtamed All materials obtained
obtained easily. obtained easily. easily. easily.
None needed. Building demolition Building demolition Building demolition
equipment obtained equipment obtained equipment obtained
easily. easily. easily.
lil39,844 :sl,u84,881 li'l,840,000 ~o.150,000
$ 4,uuu $ ~.uw $ u li u
$20,000 * $ 20,000 *
$255,0'I0 $1,345,0'IU ;v;,840,uw ~o,150,000
** Present worth calculated using a discount rate of 5% and 30-year life where O&M costs are included.
- - -
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 40
' ;'
Alternative 6
Off-Site Incineration
Would not interfere
with any future
actions.
Same as Alternative 4.
State may object to
sending materials out
of state.
All materials obtained
easily.
Building demolition
equipment obtained
easily.
$17,100,000
li u
$17,100,000
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 41
from coming into dermal contact or ingesting contaminated soil, Property deed restrictions would also be established to put limitations on the future use(s) of the property, thereby further reducing the possibility of future residents or workers coming into dermal contact or ingesting contaminated soil, The capital costs as well as the -operation and maintenance costs associated with Alternative Two are shown below.
Capital Costs
Present Worth o & M Costs
Total Prese~t Worth Costs
$ 0
~ 255,640 255,640
Alternative 3: Demolition of Buildings and Capping
As with Alternatives 1 and 2, Alternative 3 would not involve remediation of contaminated soil. However, the existing structures (i.e., buildings and paved areas) would be demolished and transported off-site to an appropriate disposal facility, The areas known to have surface soil contamination would then be capped or paved to reduce the possibility of future residents or workers coming into dermal contact or ingesting contaminated soil. Capping would also reduce the possibility of contaminants leaching from the soil into the groundwater. Property ,deed restrictions would be established to place limitations on/ the future use(s) of the property. The capital costs as well as the operation and maintenance cost's associated with Alternative Three are shown below.
Capital Costs
Present Worth O·& M Costs
Total Present Worth Costs
$ 0
1 345 640
1,345,640
Alternative 4: Demolition of Buildings, Soil Excavation and On-site Treatment Using Thermal Desorption and Base Catalyzed Decomposition
Alternative 4 would inv.olve demolishing the existing buildings, then excavating and treating approximately 6,945 cubic yards of contaminated soil on-site with Thermal Desorption and Base Catalyzed Decomposition (BCD) . Thermal Desorption is a process which uses either direct or indirect heat exchange to heat organic contaminants to a temperature high enough to separate them from a contaminated solid medium such as soil. After being condensed and treated in the BCD process, all organic residuals would be transported off-site for further treatment and disposal. Particulate matter is removed by conventional air pollution control methods.
The treated soil would be backfilled into the excavated areas, after which the S'ite would be regraded and seeded with grass.
Trenches would also be dug in areas currently beneath the warehouses in an attempt to locate the alleged pesticides burial pit. A treatability study may be needed to evaluate the process viability of the contaminated soil, as well as to establish design and operating parameters for the optimization of the treatment system. A determination will be made during the remedial design phase as to the need of the treatability study. The capital and operation and maintenance costs for Alternative 4 are shown below.
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Present! Worth O & M Costs
Total Present Worth Costs
$ 4,840,000
~ 4,840,00g
FINAL ROD
November 1994 FCX-STATESVILLE OU2
PAGE 42
Alternative 5: Demolition of Buildings, Soil Excavation, and On-site Treatment Using Thermal Desorption and an alternate method of treating offgases
Alternative 5 would involve demolishing the existing buildings, then excavating and treating approximately 6,945 cubic yards of contaminated soil on-site using Thermal Desorption and an alternate method of treating the offgases. Organics in the offgases may be collected and recovered on-site by condensation and adsorption. Any concentrated and condensed organic contaminants remaining after the process would be stored for shipment to recycling centers or off-site treatment facilities, such as incinerators. Particulate matter would be_ removed by conventional air pollution control methods.
The treated soil would be backfilled into the excavated areas,' after which the Site would be regraded and seeded with grass. Trenches would be dug beneath the existing warehouses in an attempt to locate the alleged pesticide burial pit. As with Alternative Four, a treatability study may be ne_eded as part of Alternative Five to evaluate the process viability of the contaminated soil, as well as to establish design and operating parameters for the optimization of the treatment system. The capital and operation and maintenance 'costs associated with Alternative 5 are shown .below.
Capital Costs
Present Worth O & M Costs Total Present worth Costs
$ 6,150,000
~ 6,150,00g
Alternative 6: Demolition of Buildings, Soil Excavation, and Off-site Treatment Using Incineration
Alternative 6 would involve demolishing the existing buildings, then excavating and transporting approximately 6,945 cubic yards of contaminated soil'. offsite to an EPA-approved incineration facility for treatment. Clean soil would be transported to the Site and backfilled into the excavated areas. The Site would then be regraded and seeded with grass.
I Trenches would be dug beneath the existing warehouses in an attempt to locate the alleged -pesticide burial pit. -The capital and operation and maintenance costs associated with Alternative 6 are shown below.
Capital costs
Present Worth O & M costs Total Present Worth Costs
$17,100,000
~17,100,00g
X. SIJMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives to address soil contamination were each evaluated using the nine evaluation criteria as set forth in the \
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NCP, 40-{:FR 300 .430 (e) (9). A brief description of each of the nine evaluation criteria is provided below.
The nine evaluation criteria summarized above relate directly to requirements in Section 121 of CERCLA, 42 U.S.C. § 9621, which determine the feasibility and acceptability of the remedy. Threshold criteria must be satisfied in order for a remedy to be eligible for selection. -Primary balancing criteria are used to weigh major tradeoffs between remedies. State and community acceptance are modifying criteria formally taken into account after public comment is received on the Proposed Plan. The following paragraphs provide brief summaries of the nine evaluation criteria, followed by a summary of how each of the six alternatives was evaluated against the nine criteria.
THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment addresses how an alternative as a .whole will protect human health and the environment. This includes an assessment of how any unacceptable risk to human health and the environment is properly eliminated, reduced, or controlled through the treatment of hazardous waste, or with engineering controls or property deed restrictions placed on the property to restrict access and ( f1uture) development.
Compliance with Applicable or Relevant' and Appropriate Requirements (ARARs) addresses whether or not a remedy complies with all state and federal environmental and public health laws and requirements · that apply or are relevant and appropriate to the conditions and .cleanup options at a specific site. If an ARAR cannot be met, the analysis of the alternative must provide the grounds for invoking a statutory waiver.
PRIMARY BALANCING CRITERIA
Short-term Effectiveness refers to the likelihood of adverse impacts on human health or the environment that may be posed during the construction:and implementation of an alternative until cleanup levels are achieved.
Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain reliable protection of human health and the environment over time once the cleanup levels have been met.
Reduction of Toxicity, Mobility, or Volume are the three principal measures of the 'overall performance of an alternative. The 1986 amendments to the Superfund emphasize that, whenever possible, EPA should select a remedy that uses a treatment process to permanently reduce -the level of toxicity of contaminants at the site; the spread _o.f__ contaminants away from the source of contaminants; and the volume, or amount, of contamination at the site. '
Implementability, refers to the technical and administrative feasibility of 'an alternative, including the availability of materials and services needed to implement the alternative.
Cost includes the capital (up-front) cost of implementing an alternative, as well as ·the cost of operating and maintaining the alternative over the long-term, and the net present worth of both I
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the capital and.operation and maintenance costs.
MODIFYING CRITERIA
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 44
State Acceptance address.es whether, based on its review of the
RI/FS and Propos,ed Plan, the State concurs with, opposes, or has no
comments on the alternative EPA is proposing as the remedy for the Site.
Community Acceptance addresses whether the public concurs with
EPA's Proposed Plan. Community acceptance of the Proposed Plan is.
evaluated based ·on verbal comments received at the public meetings
and those written comments received during the public comment period.
Overall Protection of Human Health and the Environment
Each alternative was evaluated to determine whether it would
effectively mitigate and minimize the long-term risks to public
health and the environment due to dermal contact and ingestion of
contaminated soil at the Site. Alternative 1 would not be
protective of human health or the environment since soil
contamination would not be addressed; therefore, unacceptable risks
would not be mitigated and the contamiriated soil would continue to
exist as a source of groundwater contamination. Furthermore, no
deed restrictions would be implemented to restrict the future land
use of the Site.
Alternative 2 would be partially protective of human health and the
. environment because the .capping of contaminated soil around the
warehouses would help reduce the possibility of dermal contact and
ingestion of contaminated surface soil, as well as the potential
leaching of contaminants from the soil into the groundwater.
However, Alternative 2 would be protective over the long term only
if the deed restrictions were effectively implemented on the FCX
property. Furthermore, since no active remediation of the soil
would take place under Alternative 2, the contaminated soil would
continue to exis:t as a source of groundwater contamination.
Alternatives 4, 5, and 6 would be protective of human health and
the environment because the unacceptable risks associated with the
contaminated soil would be reduced to acceptable levels. Total
pesticides in the surface and subsurface soil would also be reduced
by an estimated 98. 4 % as an existing source of groundwater contamination.
Compliance with ARARs
There are no chemical-specific ARARs for the soil at the Site.
However:.~the remediation levels established for Site-related
contaminants in 'the surface soil at the FCX-Statesville Site are
based on 10-6 risk. The pesticide penta-chlorophenol is the only
Site-related contaminant identified in the surface soil at the Site
at concentrations which exceed 10-6 risk. EPA has established a
remediation level of 3.2 parts per million for pentachlorophenol in
the surface soil. This remediation level reduces the risk
associated with dermal contact and ingestion of pentachlorophenol
in the surface sbil to 10-6 •
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EPA has~established the remediation level for total pesticides in
the surface and subsurface soil at the Site at the one part per
million. EPA believes that remediating total pesticides in the·
surface and subsurface soil to the one part per million level will
effectively remove appro~imately 98.4 % of the total pesticides in
the soil as a source of groundwater contamination. Combined with
the Operable Unit One groundwater pump-and-treat system, EPA
believes this 98.4 % reduction of total pesticides in the surface
and subsurface soil will be protective of human health and the
environment.
Short-term Effectiveness
Alternatives 1 and 2 could be easily implemented because both
alternatives involve conducting 5-year reviews, and limited capping
for alternative 2. Alternatives 1 and 2 would not reduce the site-
related contamination on ·a short-term basis.
Alternatives 3, 4, 5, or 6 would involve potential physical hazards
to workers during warehouse demolition and remedial action
activities. For .this reason, EPA will require a Health and Safety
Plan (following OSHA guidelines) to be developed and followed by
all remedial workers throughout the Operable Unit Two Remedial
Action. Alternatives 3, 4, 5, and/ 6 would also involve the
generation of dust. However, these alternatives will be designed,
so that dust would be minimized and controlled with water sprayers.
Long-term Effectiveness and Permanence
Alternatives 1, 2, and 3 would have no effect on the contaminant
concentrations contributing to the risks identified in the Baseline
Risk Assessment. Capping of portions of the Site under
Alternatives 2 and 3 would help mitigate the potential for dermal
contact and inges'tion of contaminated surface soil, as well as the
leaching of contaminants from the soil into the groundwater.
However, the long-term effectiveness of these two alternatives
would depend on the effectiveness of the property deed
restrictions. On the other hand, Alternatives 4, 5, and 6 are
permanent remedie's, and therefore would be effective over the long-
term.
Reduction of Tox~city, Mobility, or Volume
Since Alternatives 1, 2, and 3 provide no active treatment of the
contaminated soil, contaminants would degrade only by passive,
natural processes. On the other hand, Alternative 4, 5, and 6
would effectively reduce the volume of pesticides in the soil by an
estimated 98. 4 %:, thereby reducing the toxicity, mobility, and
volume of the contaminants in the soil.
Impleme~bility
The five-year reviews would be easily ·implemented as part of
Alternatives 1, 2, and 3; however, extensive coordination is needed
between the State: and local agencies in order to implement the deed
restrictions necessary for the effective implementation of
Alternatives 2 and 3. Alternatives 4, 5, and 6 are implementable,
but would require both · detailed design preparation · and coordination.
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Cost
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 46
Estimated total present worth costs for the five soil alternatives
for Operable Unit Two are presented below; the costs assume a 5%
interest rate.
Alternative 1 : $55,640
Alternative 2: $255,640
Alternative 3: $1,345,640
Alternative 4: $4,840,000
Alternative 5: $6,150,000
Alternative, 6: $17,100,000
State Acce12tance
The NCDEHNR has reviewed and provided ~PA-Region IV with comments
on the Remedial Investigation and Feas'ibility Study reports. The
NCDEHNR also reviewed this Record of Decision and EPA's preferred
alternative and concurs with EPA's selection.
Community Acce12tance
Each comment has been included in the Responsiveness Summary, and
is included as Appendix B of this Record_ of Decision (ROD).
XI. THE SELECTED REMEDY
Based on ·consideration of the requirements of CERCLA, the NCP, the
detailed analysis of alternatives, as well as state and public
comments, EPA has select_ed Alternative Four for the Operable Unit
Two Remedial Action at the FCX-Statesville Superfund Site.
Alternative Four will involve treating approximately 6,945 cubic
yards of contaminated soil on-site using Thermal Desorption and
Base Catalyzed D:ecomposition (BCD) . Thermal Desorption and BCD
have proven effective in the treatment of halogenated volatile
organic compounds, halogenated semi volatile organic compounds,
pesticides, herbicides, and dioxin/furans in soil. Implementation
of the Operable Unit Two Remedial Action must be in compliance with
all ARAR.s_listed in Tables 6 and 7.
The total present worth ·cost of Alternative Four ( assuming a 5%
interest rate) is approximately $4,840,000. Table 10 shows the
capital costs and the operation and maintenance costs associated
with Alternative'Four.
Alternative Four will involve a number of activities. Following the
completion of the_Remedial Design, equipment will be transported to
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FCX-STATESVILLE OU2
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the Site. The existing _buildings and asphalt parking lot will be
demolished and the demolition rubble transported off-site to an
appropriate disposal facility. An estimated 6,945 cubic yards of
contaminated soil will then be excavated and stockpiled on-site in
a manner which minimizes dust emissions and runoff. Soil samples
will be collected beneath the excavated areas and analyzed to
ensure that soil remaining on the FCX property contains less than
the risk-based remediation level for pentachlorophenol (3.2 parts-
per-million in the top one foot of soil), and the remediation level
for total pesticides (one part-per-million in surface and
subsurface soil). Trenches will also be dug beneath the areas
presently covered by the· warehouses in an attempt to locate the
alleged pesticide burial pit.
EPA believes the contaminated soil is not RCRA Listed Hazardous
Waste because th_e contamination is thought to have resulted from
spillage and not from deliberate dumping. However, if EPA obtains
evidence during the Remedial Action which indicates that the soil
is RCRA Listed Hazardous Waste, then all ARARs listed in this
document regarding the storage, treatment, and disposal of RCRA
Listed Hazardous Waste will be met.
During the Remedial Design Phase, EPA will determine if the
contaminated soil is RCRA Characteristic Hazardous Waste by
collecting and ' analyzing soil samples using the Toxicity
Characteristic Leaching Procedure (TCLP) . Only if the TCLP
_ indicates that the soil is RCRA Characteristic Hazardous Waste,
will the ARARs listed in this document regarding the storage,
treatment, and disposal of RCRA Characteristic Hazardous Waste be
met.
The contaminated soil will be treated on-site with Thermal
Desorption and the Base Catalyzed Decomposition (BCD) process.
Once the soil has passed through the treatment system, verification
samples will be collected and analyzed to ensure the treated soil
contains levels of pentachlorophenol and total pesticides equal to
or below 3.2 parts per million and one part per million,
respectively. The treated soil will then be backfilled into the
excavated areas, and the Site will be regraded and seeded with
grass. Regrading and seeding the Site will reduce the possibility
of erosion and he.lp to enhance the appearance of the FCX property.
XII. STATUTORY DETERMINATION
Based o1l....sl_vailable information, the selected remedy satisfies the
remedy selection requirements under CERCLA, as amended by SARA, and
the NCP. The sel-ected remedy provides protection of human health
and the environment, complies with all ARARs, is cost-effective,
utilizes permanent solutions to the maximum extent practicable, and
satisfies the statutory preference for remedies involving treatment
technologies.
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APITAL COSTS
PROJECT PLANS
EROSION CONTROL(LIN.FT.)
MOBILIZATION
WAREHOUSE DEMOLITION·
TREATABILITY STUDY
EXCAVATION AND MITD
WITH BCD
EXCAVATION (CY)
MTTD WITH BCD (TONS)
TRANSPORTATION (TONS)
VERIFICATION SAMPLES
BACKFILL (CY)
REGRADE/RESEED(ACRES)
O& MCOSTS
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9,376
0
50
6,945
2
TABLE 10
Cost Estimate
for Alternative 4
40,000
3
0
650,000
. 40,000
0
250
0
350
0
1,500
40,000
6,000
0
650,000
40,000
0
2,343,938
0
17,500
0
3,000
0
SUBTOTAL CAPITAL 3,100,438
ENGINEERING, ADMINISTRATION (%) 25 775,109
CONTINGENCY (%) , . 25 968,887
FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 48
SITE PERIMETER (5 ACRES)
INCLUDES DECON AND DISPOSAL
LAB BENCH SCALE STUDY
INCLUDED IN TURNKEY PRICE
100 PCF (TURNKEY PROJECT PRICE)
PESTICIDES, PCP, DIOXINS ANALYSIS
INCLUDED IN TURNKEY PRICE
2 AC
NOTE: Present worth equals capital costs since there are no furure O&M costs for this alternative. Value shown has been
rounded to the nearest $10,000.
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I Protec~ion of Human Health and the Environment
The selected remedy will permanently treat the contaminated soil, reduce the risks' associated with the dermal contact and incidental ingestion of contaminated surface soil, and reduce the amount of total pesticidei in the surface and subsurface soil as a source of groundwater cont·amination.
Compliance with ARARs
The selected remedy will comply with all Federal and State ARARs. No waivers of Federal or State requirements are anticipated for Operable Unit Two at this Site.
Cost Effectiveness
The selected soil treatment technologies are more cost-effective than the other acceptable alternatives considered. The selected remedy provides greater benefit for the cost because it permanently treats the waste 'and is acceptable to both the regulatory and local communities.
Utilization of :Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable
I . The selected remedy represents the maximum extent to which permanent solutions and treatment can be practicably utilized for this Remedial Action.
Of the alternatives that are protective of human health and the environment and comply with ARARs, EPA-Region IV and the State have determined that the selected re~edy provides the best balance of trade-offs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume achieved through treatment; short-term effectiveness, implementability, and cost; State and community acceptance; and the statutory preference for treatment as a principal element.
Preference for Treatment as .a Principal Element
The preference for treatment is satisfied by the use of Thermal Desorption and Base Catalyzed Decomposition on the contaminated soil. _ The principal ri"sk associated with the contaminated soil will bE;._.mitigated by the use of these treatment processes.
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I APPENDIX A
I-STATE CONCURRENCE LETTER
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State of North Carolina Department of Environment, Health and Natural Resources
-Division of Solid Waste Management
James s·.'Hunt, Jr., Governor
Jonathan 8. Howes, Secretary
William L. Meyer, Director
Mr. Ken Mallary
Remedial Project Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 3036~
November 2, 1994
.AV'A
DEHNR
RE: state Concurrence with the Record of Decision FCX Statesville NPL Site Operable Unit 2, Soil NCD 024 644 494
Statesville, :_Iredell County, NC
Dear Mr. Mallary:
The State of North Carolina has' reviewed the Record of Decision (ROD) for: the FCX Statesville-NFL Site for operable unit 2 (Soil) and condurs with the. selected remedy, subject to the following conditions.
1. State concurrence.on this Draft Record of Decision (ROD) and the selected remedy for the site is based solely on the information contained in the Draft Final Record of Decision': dated October 1994; Should the State receive new or additional information which significantly affects the conclusions or remedy selection contained in the ROD, it may modify or withdraw this concurrence with written notice to EPA Region IV.
' 2. State concurrence on this ROD in no way binds the State to concur in future decisions or commits the State to participate, financially or otherwise, in the clean up of the site. The state reserves the right to review, overview, comment, and make independent assessment of all future work relating to this site.
3. The last paragraph on page 15 of the referenced ROD indicates the EPA risk range of lE-4 to lE-6 as the standard !used for establishing the risk based clean-up goals for the site. The risk level accepted in North Carolina . is lE-6. Therefore, if after remediation is complete,'the total residual risk level exceeds lE-6, the State may require deed recordation/restriction to document the presence of residual contamination .and possibly limit future use of the property as specified in NCGS 130A~310.8.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
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Mr. Mallary
11-2-94.
Page 2
4. The soil clean-up goals established in this ROD may leave concentrations of pesticides which continue to leach to groundw,ater at levels which exceed NC Groundwater Standar,ds. Continuous monitoring and tracking of the. plume over time will be required under these conditions along wlth well permit restrictions within the plume.
The sta:te of North Carolina appreciates the opportunity to comment on.the Draft Record of Decision for the subject site, and we look forward to working with EPA on the final remedy.
sincerely,
~ Jack Butler, PE
Remediation Branch Head
superfundt section ,
cc: Curt Fehn, NC Remedial Section Chief
Michael Kelly, Deputy Division Director
Randy McElveen, NC Superfund Section
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I APPENDIX B
I RESPONSIVENESS SUMMARY
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•-...: UNITED STATES
ENVIRONMENT AL PROTECITON AGENCY
REGION IV
RESPONSIVENESS SUMMARY
FCX-STATESVILLE SUPERFUND SITE
OPERABLE UNIT TWO
STATESVILLE, IREDELL COUNTY, NORTH CAROLINA
· NOVEMBER 1994
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2.0
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TABLE OF CONTENTS
PREFACE
COMMENTS FROM NORTH CAROLINA SUPERFUND SECTION AND EPA
RESPONSES
COMMENTS FROM TECHNICAL ASSISTANCE GRANT CONSULTANT AND
EPA RESPONSES
PUBLIC MEETING .COMMENTS AND EPA RESPONSES
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1.0 PREFACE
The United States Environmental Protection Agency (EPA) held a
60-day public comment period from Jul 5, 1994 to September 3,
1994 to provide an opportunity for interested parties to comment
on the Remedial lnvestigation (RI), Risk Assessment (RA),
Feasibility Study (FS), and the EPA Proposed Plan for Operable
Unit Two at the FCX-Statesville Superfund Site in Statesville,
North Carolina. The FS evaluated various options, or remedial
alternatives, to address contaminated soil on the FCX property.
In the Proposed Plan issued in June 1994, EPA identified its
preferred alternative to address the soil contamination on the
FCX property. All of the documents for Operable Unit Two were
placed in the Administrative Record for review. The Record is a
collection of all' the documents considered by EPA when choosing
the remedy for a site. The Record was made available at the EPA
Records Center located iri the EPA-Region IV office building
located at 345 Courtland Street, NE., Atlanta, Georgia, and at
the Information Repository located in the Richard H. Thornton
Public Library located in Statesville, North Carolina.
The purpose of this Responsiveness SlllTl11lary is to document EPA
responses to the questions raised and /comments submitted during
the public comment period. EPA considered all of these questions
and comments before selecting the final remedial alternative for
Operable Unit Two to address the soil contamination on the FCX
property.
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2.0 COMMENTS FROM STATE SUPERFUND SECTION AND EPA RESPONSES
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Comment. #1
The Feasibility Study (FS) for Operable Unit 2, soils, dated June 1994 includes excavation in area 1 around sample 107. Table 6-1 of the FS also indicates the total pesticide concentration in the soil at area l/FS,-107 is 1. 35 ppm which is slightly above the 1 ppm cleanup level and PCP concentrations range up to 3.5 ppm which also exceeds the clean-up goal for PCP in soil. However, Figure 4 of the ROD only includes this area as a detect level below the 1 mg/kg, (ppm) clean-up goal. This area should be included in the 1 ppm pesticide boundary on Figure 4 rather than the detect boundary.
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EPA Response
The pesticide con~entratiori for sample location FS-107 listed in Table 6-1 and shown on Figure 6-3 of the FS Report represents a total pesticide concentration. In other words, the 1.35 ppm total pesticide concentration equals 180 ug/kg DDD, 480 ug/kg DDE, and 690 ug/kg DDT. On the other hand, Figure 4 (DDT Distribution in .Soil) only shows the concentration of DDT at sample location FS-107 (690 ug/kg). '
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3.0 COMMENTS ~OM TECHNICAL ASSISTANCE GRANT CONSULTANT
AND EPA RESPONSES ;
Comment #1
Contaminants of concern are present in groundwater at concentrations greater than would generally be expected. The Feasibility Study 'assumes the this is due to past spillage and leakage onto soils that were not covered with the asphalt and concrete that currently caps most of the site.
EPA Response
EPA has developed ~evera~ groundwater models which indicate that pesticide groundwater contamination exists at levels which can not be fully-accounted for based on. the concentrations of pesticides ·identified in the soil. However, EPA acknowledges in the Feasibility Study Report that not only spillage and leakage onto soils may contribute to the pesticide groundwater contamination, but also the alleged burial of 5,000 to 10,000 pounds of pesticides.
Comment #2
Although metals contaminate both soils and groundwater at the FCX site, these constit'uents are not addressed in either the .Risk Assessment or the Feasibility Study becc\.use no connection can be made to past site operations as the source of these contaminants. Again, because the operational history of this site goes back to the early 1940's, and is necessarily somewhat sketchy, we do not believe that metals present on-site should be discounted. At a minimum some discussion of the safety and efficacy of the proposed treatment in relation to metals contamination should be included in the Feasibility Study.
EPA Response
EPA believes the metals were adequately addressed in the Risk Assessment. The Risk Assessment does evaluate the risks associated·with potential direct contact with metals in soil, surface water, sediment, and groundwater.
Comment #3
The Feasibility Study adopts a 1 ppb soil remediation goal for PCDD on the basis of that level resulting in an acceptable 10-• _to 10-• risk. We would be interested in seeing some discussion of the validity of that soil remedial goal as risk acceptable if the EPA re-evaluation of PCDD toxicity, now in draft format, is considered. ·
EPA Response
The Draft dioxin reassessment document has recommended a minor relaxation of the Cancer Slope Factor (CSF) for TCDD and has not recommended a RfD for use in evaluating non-cancer endpoints. Using the new CSF and standard default daily exposure
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assumptions, 1.0 ug/kg of dioxin TEQs in soil equates to an upper bound risk estimate of about lE-4. The 1.0 ug/kg level will likely continue to be considered as the Agency residential soil protective· level ,during the reassessment finalization period to be completed in September, 1995.
Comment #4
We remain concerned that groundwater flow direction has been inadequately characterized. The Feasibility Study admits that the presence at this time of Lindane in an off-site well, not directly down gradient of the site is difficult to explain. Again it appears that contaminants are moving into groundwater at rates considerably greater than predicted, and contaminant plumes are being locatedin directions not previously thought to be downgradient. Obviously, this anomaly raises questions about the sufficiency of both. the planned pump and treat groundwater remediation, and the operable unit 2 soil remediation goals. Additional investigation and discussion is required to ensure that pumping wells are correctly sited and installed, and that soil remediation g·oals will be adequate to prevent further mobilization and migration of contaminants off-site. Some plan should be included in th~ Feasibility Study or the Record of Decision describing the additional worry' that will be undertaken to resolve these issues.
EPA Response
Lindane was detected in off-site temporary monitoring well T-5 at a concentration of 0.61 ppb in a direction which is downgradient from the FCX property. EPA disagrees that pesticides are moving at rates greater than predicted. EPA also disagrees that a contaminant plume was located in a direction not previously thought to be downgradient. EPA agrees that additional investigation is needed during the Remedial Design Phase to ensure that both extraction and monitoring wells are properly sited, and the OUl ROD requires such investigation. Details of the additional work to be performed will be included in the OUl Remedial Design Report, not in the ROD or FS for OU2.
Comment #5
The community's acceptance of Alternative 4 _is conditional based on the closed loop,1 on-site BCD treatment of desorption off-·gases. Because this is a residential area; even incidental emissions from the desorption unit will be unacceptable, as were the potential emissions from the proposed air stripping unit suggested for groundwater treatment.
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EPA Response
EPA agrees with the comment. For this reason, EPA will require stringent air emissions standards for the on-site thermal desorption treatment_ unit. The unit will be monitored at all times during its operation.
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Comment #6
The inclusion of 'Pentachlorophenol in remedial soil goals, although not directly attributable to on-site operations, seems inconsi·stertt when' metal/ENA contamination was excluded from consideration on ',the same basis.
EPA Response
Pentachlorophenol is classified as a pesticide, and as such can not be discounted as being a site-related contaminant. It is important to note' that the sample locations to be remediated based on total pesticide concentrations of DDT, chlordane, etc. exceeding one part-per-million, are the same sample locations which revealed the presence of pentachlorophenol.
On the other.hand; there is no indication that metals were ever used by FCX. Unlike the pesticides, the metals were detected at similar concentracions in both on-site and off-site soil samples. These widespread concentrations seem to indicate that the metals may be present as naturally-occurring elements and not as site~ related contaminants.
Comment #7
Has there been any contingency made for keeping the treatment unit on-site for use in -remediating Operable Unit 3 soils? It would be efficient to utilize a standin'g unit for required treatment, rather than incur the time and expense of shut down and dismantling of the unit, only to re-mobilize at some future point.
EPA.Response
At this point in time, there has been no proposed plan for remediating the contamination associated with the property currently owned and operated by Burlington Industries. In fact, the field work for'the Operable Unit Three Remedial Investigation is still on-going.1 EPA agrees that it would be efficient to use the on-site thermal treatment system for remediating contamination associated with Operable Unit Two and Operable Unit Three. EPA recommends that this alternative be evaluated during the development of the Feasibility Study for Operable Unit Three. . '
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COMMENTS ON RISK ASSESSMENT REPORT, REVISION 3
General Comment #1
This Revision 3 of the ~isk Assessment represents, a significant improvement in treatment of human exposure assessment.
EPA Response
EPA agrees with and' appreciates the comment.
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General Comment #2 The methodology of the Ecological Assessment Section (6), which has been the most rigorous, part of risk calculations in Revision 0, has been completely changed, resulting in a weaker and less useful presentation .. There is no exposure assessment to diverse media or explicit calculation of hypothetical risk, only comparison of selected contaminant -levels with Ambient Water Quality standards'. Thus, all consideration of dioxin/furan exposure of ecological species is precluded.
EPA Response
EPA evaluated each of the contaminants which were identified in the surface water and sediment. There was no evidence of dioxin/furans in the surface water and sediment; therefore, these contaminants ·were not evaluated in the Ecological Assessment Section.
General Comment #3 Table 3-6, Contaminants of Concern, for organic analytes, represents mostly a summary of which media were tested for a given substance, rather than substances remaining in the analysis after a screening ;process. Several compounds at significant concentrations were removed from quantitative evaluation at the stage of the Toxicity Assessment, for lack of compound-specific reference dose or cancer slope factor data, with no comment about the affect on the conservativeness of the resulting cumulative risk calculations.· The Remedial Design phase must be used to do comprehensive testing for contaminants in all media.
EPA Response
Table 3-6 not only, shows which media were tested for a given substance, but it also shows the concentrations of those substances in each:of the media. The Risk Assessment does explain which substances were eliminated from the Toxicity Assessment and why; EPA agrees with the 2nd comment. Those subs.tances eliminated from the Toxicity Assessment due to a lack of compound-specific reference dose or cancer slope factor data could have been carried forward through the risk assessment. EPA could then have mentioned the potential affects that these deletions may have .had on the qualitative risk analysis. EPA does not believe the deletion of these particular substances would have made a substantive impact on the quantitative risk -analysis.
General Comment #4
Although it is clear that dioxins/furans contribute at least 80% of the calculated c·umulative chronic and carcinogenic risk for the surface soil dermal and Ingestion pathways in the Future On-Site Resident scenario, no testing for dioxins and furans was done in other media. In particular, inclusion of a groundwater ingestion pathway, with concentrations on dioxins/furans several orders of magnitude lower than were found in surface soil, would
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cause dramatic increases in the total chronic and lifetime risk calculated, and thus could change the degree of treatment required_.for groundwater.
EPA Response .
EPA disagrees tha_t no dioxin/furans testing was performed in media other than the surface soil. Based on the presence of dioxin/furans in the soil at the Site, groundwater samples were collected from on-site monitoring wells and analyzed for dioxin/furans. The analytical results of these groundwater samples did not indicate 'the presence of dioxin or furans. None of the surface water and sediment samples collected and analyzed during the Remedial Investigation indicated the presumptive evidence of dioxin or furans. Therefore, no additional .samples were collected and analyzed specifically for dioxin and furans .,
Section 2: Site History
Section 2.1.3
This hole, filled in with pesticide waste by workers, may be a former well and, thus, a direct route to groundwater, with a potential major increase in contaminated soil and water volume. Despite this possioility, there has not/been comprehensive testing of monitoring well samples for.pesticides and limited deep sampling of the aquifer, even in the areas of highest DDT concentrations.
EPA Response
EPA has received information from a number of former employees about the day-to-day operations and disposal practices at the FCX facility on West Fr_ont Street. Most of the information sources centered around a large pesticide disposal_pit. One person claimed that waste from FCX may have been disposed in an old, abandoned well. To' this point, EPA has not been able to verify this claim-; However, EPA does feel that comprehensive testing of the groundwater across the FCX-Statesville property has been performed. Additional testing of the aquifer during the Remedial Design phase will help to further characterize groundwater conditions at the Site prior to designing and implementing the Operable Unit One p~p-and-treat system.
·Section 2 . 2 . 2
Caprolactum had been reported detected in all on-site monitoring wells, with some fairly high concentrations observed (Rev. 0). This compound appears to have been eliminated from relevant figures in Rev. 3, and was not included in any risk calculations.
EPA Response
EPA agrees with the comment. As a clarification, caprolactum was identified in most of the on-site monitoring wells in the NCDHR 1986 study. The levels of caprolactum reported in the wells_ were
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all below 18,000 ug/1, which is EPA-Region IV's screening value for caprolactum., The 18,000 ug/1 level equals a non-carcinogenic risk factor or Hazard Index value of one. ·--: __
Section 2.2.3
In results given'in the text for the weston-SPER Emergency Response of January 1989, it is stated that "no pesticides were detected in any of the samples collected outside _of the warehouse building", but no figure is presented with concentration data for pesticide analysis. This statement appears to conflict with the 1986 NCDHR study 'results reported.
EPA Response
Eight surface soil samples were collected and analyzed for pesticides· .during the Weston-SPUR Emergency Response investigation in 1989; the minimum detection limit used by the laboratory was 35,parts per billion. None of the samples indicated the presence of pesticides above the minimum detection limit.
section 2.2.8.1
No analyses are reported of groundwater samples for DDT, DDE, DDD or dioxins/furans, though there is reason to predict the presence · of both. in on-site or near off-site wel1ls. No result, are given for analyses of the Nelson.Brown well.,'
EPA Response
EPA did analyze the groundwater for DDT, DDE, DDD, and I . dioxins/furans; however, none of these contaminants were present at levels which exceeded the detection limit. The Risk Assessment did not report the analytical results of the Nels'on Brown .water supply'system; however, as stated in the RI Report, the Nelson Brown sample ·did not reveal any site-related contaminants.
Section 2.2.8.3
No samples of sediment or surface water were analyzed for dioxins/furans. PAHs found in Phase I sediment analyses were said to be "not sufficient to demonstrate that the presence of these compounds was' predominantly a function of proximity to the treated cross-ties.; .. or possibly related to past site-related contamination". Total PAHs are reported for only two samples in ·figure 2-6. Where are the results reported for the two Phase II samples collected (FS2-03-SD, FS2-04-SD) and how would two more samples, close to the tracks resolve the question of railroad-contaminated or site-associated contamination, as no other on-site samples were tested? Why were there no analyses for PAH's in water-or subsoil?
EPA Response
As stated in EPA's response to General Comment #4, there was no presumptive evidence of dioxins/furans in the surface water and
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sediment samples collected and analyzed during the Phase I Remedial Investigation. Therefore, EPA did not believe it was necessary to collect additional surface water and sediment samples-and analyze them specifically for dioxins and furans. The analytical results of samples FS2-03 SD and FS2-0,4-SD are provided in the Phase II RI Report. These results did not prove what the source of the PAHs is. Every soil, sediment, surface water, and groundwater sample collected a the Site was analyzed for PAHs. PAHs were reported for every sample in which they occurred.
Section 2.2.9
Figure 2.2.1 -dioxin/furan sample locations, is not included here.
EPA Response
EPA agrees with tne comment. As stated on page 2-31 of the Risk Assessment, Figure' 2-21 should be included to show the dioxin/furan sample locations. The figure was mistakenly left· out of the report.
Figure 2-11
No results are presented for the EPA-installed wells nearest the highest DDT concentrations on the north/side of the site. Was no DDT analysis of groundwater done on thi,s round?
EPA Response
All groundwater
the full target
including DDT.
samples.
samples collected at the Site were analyzed for compound/target analyte list constituents, DDT was not· identified in any of the groundwater
Section 3.2.1.1 and j_2.1.2
Toxicity screening methodology is more explicitly described in this revision. However, screening the average contaminant concentration against a single background sample value is of very questionable reliability.
EPA Response
Section 3.2.1.1, titled •Screening Against Background", states that the maximum on~site concentration of each constituent had to be at least two times greater than the arithmetic average of the -of the respective backg~ound samples.
Table 3-1, and Section 3.2.2.1
Monitoring well MW-4 is clearly not an appropriate source of background samples for screening of groundwater analytical values . ...:;.'he concentration of trichloroflouromethane reported is 99 mg/1, indicative that this well is within the plume of halogenated organics perhaps originating from Burlington Industries.
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EPA Response
EPA agrees with the comment. However, since this Site falls within an industrial corridor, it is not likely to locate a background well close to the Site which will provide "true" background condit:ions. As an example, the Carnation well was sampled during 1986 to provide a background sample. As it turned out, the Carnation well contained voes.
Section 3.2.1.4
For lack of "health criteria", five metals including lead and four pesticides were eliminated from quantitative evaluation of ground water exposures in this report, with no discussion as to the effect on the uncertainty of the cumulative risk. Use of the Lead Model Version 5.0 is a significant improvement over elimination of this contaminant from consideration.
EPA Response
Page 3-26 of the Risk Assessment identifies a total of nine (9) substances which were eliminated from the quantitative evaluation due to a lack of health criteria.
Table 3-6
For organic compounds, this table is functionally a chart of which media were tested for which compo,unds, rather than an indication of the media in which these/compounds present a possible hazard. The most glaring examples of this are the absence of data for most PAH's and other semi-volatile organics from groundwater and subsurface soil analysis, the absence of DDT, DDE, and DDD from groundwater analyses, and, probably most grave of all, no testing of dioxins in any media except for three samples in Area 3.
EPA Response
EPA disagrees with ',the comment. Table 3-6 shows each site-related contaminant which presents unacceptable risk in the different .media. All available data are shown for the PAHs and other semi-volatile, organics. DDT, DDE, DDD data is not presented for groundwater analyses because none of these compounds were identified in the groundwater. Thirty-eight (38) dioxin samples were collected from nineteen (19) locations in areas 1, 2, and 3, and evaluated in the risk assessment.
·Section 4. 3
One of the functions of the Conceptual Site Model is to "aid in identifying data gaps". However, this. information was not ·used to recommend further data collection.
EPA Resp3flse
EPA agrees with the.comment.
Section 4.4
It is assumed that a residence time of 30 years represents the
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90th percentile for this area. However, this is probably a figure derived from national census data and probably does not accurately represent residency patterns· in southeastern U.S. rural areas and small cities, use of more local residency data is recommended for determining a conservative estimate of exposure time of future on~site residents.
EPA Response
It is standard practice to use a residence time of 30 years as representing 90 percent of the people living across the country.
Section 4.5
Uncertainties in exposure assessment are discussed here with a much improved justlification of conservative assumptions. A semi-quantitative treatment of the sensitivity of the calculated hypothetical risk to major parameters should be included.
EPA Response
EPA does not quantify"% confidence" as it relates to the uncertainty in a exposure assessment.
Section 5.1
"The potential for carcinogenic effects, is limited to substances, that have been shown to be carcinogenic' in animal and/or humans". This statement is misleading and should be clarif-ied; the cumulative risks may only be calculated for known carcinogens, but there is undoubtedly the potential for carcinogenic effects, from as yet undemonstrated carcinogens.
EPA Response . EPA does not think this statement is misleading .. Although it is true that the potential exists for carcinogenic effects from undemonstrated carcinogens; it is unreasonable to think that the cumulative risks from undemonstrated carcinogens can be quantified until carcinogenic affects for those substances are first qualified with laboratory data.
Section 5.1.1
There remain several imprecise and unclear statements in this section, such as: "clhe range of risks, defined as the upper limit as determined by the model and the lower limit of zero needs to ·be understood by the appropriate decision makers. " A more useful and interpretable st'atement would be that assumptions and parameters used in the model, including measured concentrations of contaminants, were chosen to yield a cumulative risk figure with-% confidence that the actual risk is below this number. In order to_.nake such a statement, there must be some information given about the distribution of these parameters and the sensitivity of the calculated risk to each of them.
EPA Response
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EPA does not quantify% confidence in risk assessments.
Section 5.4
Acknowlecl:ging the uncertainties associated with extrapolating from oral to dermal pathways, the method used for approximating dermal reference doses and dermal cancer slope factors seems a reasonable one. Here is· a case, however, where the confidence that a calculated cumulative risk is below a certain level would be increased by using a safety factor in transforming to another I pathway.
EPA Response
Safety or "uncertainty" factors are already included in the oral values. EPA agrees the dermal adjustments add to the uncertainty in the risk assessment process, but EPA believes this is a conservative adjustment.
Uncertainty Analysis
This section more clearly enumerates the major contributors to uncertainty in the risk calculations, but should include at least a semiquantitative statement about the magnitude and direction of the contribution made by each (i.e., a sketchy sensitivity analysis). It should be pointed out that exclusion of substances whose specific RfDrs and CSFs are not d~termined is a potentially significant source of error in the direction of underestimation of cumulative risk.
EPA Response
EPA does not quantify uncertainty in the Risk Assessment process. EPA agrees with the second ·comment that the exclusion of substances whose RfDs and CSFs are not determined is a potential source of error in the direction of underestimation of cumulative risk.
Section 6: Ecological Risk Assessment This section, the most rigorous of the Rev. 0 Risk Analyses, has been completely transformed, with the elimination of a detailed· and rational exposure model for the American Robin. Instead, a limited selection of water contaminants is screened against Ambient Water Quality standards, altogether eliminating assessment of exposure to the most toxic on site contaminants, dioxins and furans.
EPA Response
Each of the substances-identified in surface water and sediment samples during the RI were first screened against background and concentration-toxicity data. EPA then evaluated each of substances-identified in surface water and sediment against the Ambient Water Quality Standards. The reason why dioxin/furans were not evaluated in the Ecological Risk Assessment was because there was no presumptive evidence of dioxin/furans in the surface water and sediment samples collected and analyzed during the
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RI/FS; therefore,, no samples were collected and analyzed specifically for 'dioxin/furans.
I Tables 6~6 and 6-7
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Contaminants of Concern. As in Section 3, this list is based less on a rational screening process for analyzed substances on which chemicals·were analyzed in a given medium. .
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EPA Response
EPA would like to·point out that, unlike Table 3-7 in Section 3, the titles for Tables 6-6 and 6-7 do not mention "Contaminants of Concern", but "Contaminants in Surface water" and "Contaminants Detected in Sediment", respectively.
Section 7: Risk Characterization This Risk Characterization suffers from the non-evaluation of several contaminants, efther because toxicity data were not available for the particular compound or because analysis was not performed for toxic compounds which should have been expected in all media. Given the presence of chlorinated solvents, polyaromatics and pesticides, dioxins/furans should have been analyzed extensively in all media. Air monitoring data described qualitatively here should have been included in tabular form in section 2 of this risk analysis.
The uncertainty analysis for this section is completely inadequate (see comments ·on other uncertainty subsections) and fails to mention the non-conservative effect of removal of all contaminants lacking health criteria from the risk calculations.
EPA Response
EPA evaluated all site-related substances that were identified during the Remedial', Investigation, including dioxins/furans. Soil was the only medium in which presumptive evidence of dioxin/furans was identified. As a result, EPA collected soil and groundwater samples and analyzed them specifically for dioxin/furans. Although dioxin and furans were identified in the soil at levels below 1 ppb (TEQ), no dioxin or furans were identified in the groundwater.
EPA agrees with the comment regarding the uncertainty section. EPA should have included a discussion in the Risk Charac--terization Section regarding the lack of toxicity values for certain contaminants, and the potential affects of excluding these contaminants from the risk evaludtion.
Section 8: Remedial Goal Options
Tables 8-1 and 8.-2 .. This explicit presentation of the clean-up goals for individual' contaminants in order to achieve various hypothetical risk levels is informative, and, in the case of Table 8-2, provides a helpful comparison with state and federal
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regulatory level~ for drinking water. As analysis for several compounds, was not carried out comprehensively in all media (most importantly, for dioxins/furans in ground water), this table can only be·-used for :prelimi"nary guidance in estimated soil and water volumes requiring treatment. Only if far more comprehensive testing occurs during the Remedial Design phase, especially for dioxins/furans, Jill such calculations rationally guide clean-up level decisions.
EPA Response
As stated in previous responses, EPA believes that a comprehensive eva:luation of all site-related substances was carried out. EPA' does not believe that additional testing for dioxins/furans in groundwater is necessary due to the fact that neither of these constituents was identified in on-site monitoring wells during the Remedial Investigation.
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regulatory level_s for drinking water. As analysis for several compounds, was not carried out comprehensively in all media (most importantly, for dioxins/furans in ground water}, this table can only be-\is·ed for prelimi'nary guidance in estimated soil and water volumes requiring treatment. Only if far more comprehensive testing occurs during the Remedial Design phase, especially for dioxins/furans, will such calculations rationally guide clean-up level decisions.·
EPA Response
As stated in previous responses, EPA believes that a comprehensive evaluation of all site-related substances was carried out. EPA does not believe that additional testing for dioxins/furans in groundwater is necessary due to the fact that neither of these ~onstituents was identified in on-site monitoring wells during the Remedial Investigation.
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