NCD095458527_19960725_FCX Inc. (Statesville)_FRBCERCLA RI_Remedial Investigation Feasibility Study 1990 - 1996-OCR

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FCX, INC.
Statesville, North Carolina
EPA'S PROPOSED PLAN
MEETING AGENDA
July 25, 1996
N. B. Mills Elementary School
1410 Pearl Street .
Statesville, North Carolina
RI/Fs
f>f
AGENDA
Welcome, Introduction and Purpose
Of Meeting
Brief Site History and Summary of
OU3 Proposed Alternatives
..
McKenzie Mallary
EPA Project Manager
Question & Answer Period
NOTES
Closing Remarks
SU~RFUND PROPOSED PL~ FACT SHEET,
OPERABLE UNIT #3
4
FCX-STATESVILLE SITE
Region 4 Statesville, Iredell County, North Carolina
July 1996
This fact sheet is one in a series of fact sheets prepared as an informational document for the public and is not to be ccnsdered as a technical document.
INTRODUCTION: This Proposed Plan identifies the preferred 2. Presents the alternatives for the Site considered by EPA;
Outlines the criteria used by EPA to recommend an
alternative for use at the Site;
options for cleaning up contaminated soil and groundwater for
Operable Unit #3 at the FCX-Statesville Supertund Site in 3.
Statesvlle, North Carolina. ( Terms in bold face print are defined
in a glossary located at the end of this publication). This
document is being issued by the U.S. Environmental Protection 4.
Agency (EPA), the lead agency for Site activities, and the North
Provides a summary of the analysis of alternatives;
Presents EPA's rationale for its preliminary selection of the
preferred alternative; and
Carolina Department of Environment, Health and Natural 5.
Resources (NC DEHNR), the support agency. Aquaterra ,
technical consultant for Burtington Industries and El Paso Natural
Gas Co., conducted the Remedial Investigation (RI) and 6. Explains the opportunities for public to comment on the
remedial alternatives. Feasibility Study (FS) with the supervision of EPA and
NCDEHNR. EPA and NCDEHNR will select a remedy for
Operable Unit 3 only after the public comment period has ended,
. and all information submitted to EPA during this time has been
reviewed and considered.
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 11 ?(a) of the
Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA), also known as Supertund.
This document summarizes information that is explained in
greater detail in the Remedial Investigation/Feasibility Study
reports and other documents contained in the Information
Repository/ Administrative Record for this Site. EPA and the
State encourage the public to review these documents to better
understand the Site and the Supertund activities that have been
conducted. The Administrative Record is available for public
review locally at the Iredell County Library in Statesville, North·
Carolina.
EPA, in consultation with NC DEHNR, may modify the preferred
alternative or select another response action presented in this
. Plan and the Remedial Investigation/Feasibility Study Reports
based on new information and/or public comments. Therefore,
the public is encouraged to review and comment on all
alternatives identified here.
THIS PROPOSED PLAN:.
1. Includes a brief history of the Site and the principal findings
of Site investigations;
PUBLIC MEETING
WHEN: July 25, 1996
TIME: 7:00 PM -9:00 PM
WHERE: N.B. Mills Elementary School
1410 Pearl Street
Statesville, NC
PUBLIC COMMENT PERIOD:
July 1 B -August 1 B, 1996
BRIEF SITE DESCRIPTION
The FCX property occupies about 5.5 acres at the intersection of
Phoenix Street and West Front Street, in Statesville, Iredell
County, North Carolina, approximately 1.5 miles west of
downtown Statesville. FCX (Farmers Cooperative Exchange)
began operations as an agricultural supply distribution center in
1940, and continued to operate until 1986 when FCX declared
bankruptcy.
From 1986 to 1990, a number of environmental studies were
pertormed at the FCX property to determine if contamination
existed at the property. These studies indicated the presence of
both pesticide and volatile organic compound contamination in
the soil and groundwater at the FCX property. Based upon the
•
Hazardous Ranking Score of how ~e contaminants could
· affect human health or the environ me.A proposed and then
placed the FCX Site on the National Priorities List in November
1990.
From 1991 to 1993, EPA-Region IV conducted a Remedial
Investigation at the Site. An extensive number of soil, surtace
water, sediment, and groundwater samples were collected to
characterize the nature and extent of contamination at the Site,
· The results of the Remedial Investigation confirmed the presence
of pesticide and volatile organic compound contamination in the
soil and groundwater at the Site.
The scurce(s) of the volatile organic compound contamination in
the groundwater was not identified during the Operable Unit 1
Remedial Investigation, and EPA suspected that.the source(s) of
this contamination was possibly associated with one or more
industrial properties located in the immediate area of the FCX
property. EPA-Region IV subsequently met with representatives
from Burlington Industries, Beaunit Corporation, and Carnation
Milk Company to discuss the possibility of negotiating a
settlement whereby they would conduct a separate Remedial
Investigation to characterize the extent of the volatile organic
compound contamination, including the source(s) of this
contamination. Following the meeting, Burlington Industries
hired a consultant to collect soil and groundwater samples from
their property. The results of this study revealed the presence of
elevated levels of volatile organic compounds in the soil and
groundwater on the Burlington property.
The FCX-Statesville Supertund Site was subsequently expanded
to include the Burlington property based on the following
information. First, the Hazardous Ranking System scoring
pack.age used to place the FCX-Statesville Site on the national
Priorities List clearly includes the presence of volatile organic
compounds in the groundwater. Second, the pesticide and
volatile organic compound contamination have consistently been
detected in the same monitoring wells on the FCX property.
Therefore, any attempt at treating the groundwater for pesticide
contamination would also require treating the groundwater for
volatile organic compound contamination. By expanding the
boundary of the FCX-Statesville Site to include the Burlington
property, EPA will be able to address the contamination
associated with the Burlington property.
On June 25, 1993, EPA-Region IV signed an.Administrative
Order on Consent with Burlington Industries, as well as the
former property owner El Paso Natural Gas Company, to conduct
the Operable Unit Three Remedial Investigation and Feasibility
Study to investigate the contamination associated with the
Burlington Industries property.
TEXTILE FACILITY SITE HISTORY
A textile plant was constructed in 1927 on the property presently
owned by Burlington..ai!ustries. From 1955 to 1977 the plant
was operated by B•it Mills. In 1967 Beaunit became a
subsidiary of the El Paso Natural Gas Company. In April 1977
Beaunit sold substantially all of its assets, including the plant, to
Beaunit II, Inc. As a part of that transaction, Beaunit changed its
name to BEM Holding Corpo,ration, and Beaunit II, Inc. changed
Its name to the Beaunit Corporation. In July 1978 the plant was
scld by the Beaunit Corporation to Beaunit Fabrics Corporation ..
In 1981, Burlington Industries, Inc. purchased certain assets,
including the plant, from Beaunit Fabrics. Burlington operated
the plant until its closure in May 1994.
It is believed that at various times the plant process several kinds
of yarns and fibers, including cotton, nylon, rayon, elastic nylon,
wool, and polyester. It is also believed that at various times the
plant may have pertormed single, double, and circular knitting, as
well as weaving, dyeing, finishing, and heat transfer printing.
RESULTS OF REMEDIAL INVESTIGATION
The Remedial Investigation for Operable Unit #3 undertaken by
the Potentially Responsible Parties (PRPs) was conducted by
their contractor, Aquaterra, Inc., Raleigh, North Carolina. The
investigation of soil and groundwater began in February 1994
involving three Phases.
► Phase I included a soil gas survey, soil sampling at
specified areas, sampling of existing FCX and study area
wells, and sampling of sediment and surtace water.
► Phase II included scil sampling at study areas to define the
extent of any impacts, monitoring well installation and
sampling, and collection of geologic and hydrologic
information.
► Phase Ill included additional monitoring well installation
and sampling, soil and groundwaier sampling with dir_ect
push techniques, surtace water sampling, and collection of
hydrogeologic information.
Results of these sampling activities indicated elevated levels of
the following contaminants of concern in groundwater or soil: ·
Arsenic
Manganese
Barium
bis(2-Ethylhexyl) Phthalate
Chloroform
cis-1,2-dichloroethene
Methylene Chloride
1, 1,2-trichloroethane
Vinyl chloride
2-Hexanone
Iron
Aluminum
Lead
Carbontetrachloride
1, 1-dichloroethene
1,2-dichloropropane
Tetrachloroethene
Trichloroethane
Arochlor 1260
2-Methylnaphthalene
REMEDIAL ACTION OBJECTIVES
Remedial action objectives were develd based on the results · of the Risk Assessment, and the examination of potential Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs). ARARs are categorized as Action-,
location-, and chemical-specific. Chemical-specific ARARs for
groundwater include Federal Maximum Contaminant Levels
(MCL) and North. Carolina Groundwater Standards. Location-
specific ARARs address site-specific conditions such as critical
habitat upon which endangered species or threatened species depend, the presence of a wetland, or historically significant features. Action-specific requirements are controls or restrictions for partiOJlar activities related to the implementation of a remed'1al alternative. "
RISK ASSESSMENT
Exposure scenarios for both current and future land use were
evaluated. based on an estimate of Reasonable Maximum
Exposure (AME). Under the current land use scenario, current
human receptors near the site potentially include residents living
adjacent to the Site who may incidentally ingest or come into
contact with contaminated groundwater or surtace water. Under
the future land use scenario, future human receptors would be on-site residents who ingest, inhale, or come into direct contact with contaminated groundwater or soil.
A qualitative ecological assessment was pertormed at the Site
during the Remedial Investigation. No unique or sensitive
habitats were identified at or near the Site. The principle pathway
for surtace water and sediment contamination to migrate off-site
is via groundwater discharge into the surtace water seep area located immediately to the north of the textile facility.
SUMMARY OF SITE RISKS
The chemicals of concern (COCs) for an exposure scenario are
the chemicals of potential concern (COPCs) that significantly
contribute to an exposure pathway for an identified receptor. A
COC must have a cumulative carcinogenic risk which exceeds
1x10'', or a hazard index (HI) for noncarcinogenic risk of 1.0. A 1 x1 o• cumulative ·carcinogenic risk level or an HI of 1.0 for noncardnogenic risk are typically used as "remediation triggers". The only exposure scenario which exceeds the 1 x10,.
carcinogenic risk or an HI of 1.0 for noncarcinogenic risk is the hypothetical future on-site resident ingesting and inhaling contaminated groundwater.
Potential current arid future exposures to surtace water in the
seep area, and the intermittant streams located to the east and to the south of the Site by local adolescents are within acceptable ~Q~. . .
. SUMMARY OF RE,IAL ALTERNATIVES
The following section provides a summary of the alternatives
developed in the Fl)!lsibility Study for remediation of the Site.
The primary objective of the Feasibility Study was to determine
and evaluate alternatives for cleaning up contaminated soil and
groundwater emanating from the Burlington property.
Descriptions of the clean-up alternatives are summarized below.
The Feasibility Study contains a more detailed description and
evaluation of each alternative, and is available for review in the
information repository ..
The cost information provided below for each alternative
represents estimated capital cost, and the present worth of the annual operation and maintenance (O&M). Capital cost includes
construction, engineering and design, equipment. and Site development. Operating costs were calculated for activities that
continue after completion of construction, such as routine
operation and maintenance of treatment equipment, and
monitoring. The present worth (PW) of an alternative is the
amount of capital required to be deposited at the present time at a given interest rate to yield the total amount necessary to pay for
initial construction costs and future expenditures, including.
Operation & Maintenance and future replacement of capital
equipment.
ALTERNATIVES TO ADDRESS GROUNDWATER
CONTAMINATION
ALTERNATIVE GA-1: NO ACTION
Total PW Costs: $55,640
CERCLA requires that the No Action alternative be evaluated at every Site to establish a baseline for comparison. Under this alternative, no further action would be taken at the Site to remove or control groundwater contamination. The groundwater would
be monitored and recorded semiannually and a review of remedy
would be conducted every five years in accordance with the requirements of CERCLA. Operating costs are based on semi-annual sampling and five year reviews. Five-Year reviews would be conducted for 30-years; the present worth costs forthe five-
year reviews is $55,640.
ALTERNATIVE GA-2: LIMITED ACTION
Total PW Costs: $2,776,300
This alternative would utilize deed restrictio~s to restrict access to contaminated groundwater on-site. This. alternative also requires the long term monitoring of Site groundwater based
upon 30 years of monitoring. Sampling would be conducted on
existing wells on an semi-annual basis. Five-Year Reviews
would be conducted for 30 years.
ALTERNATIVE GA-3: AIR SPARGl!,iJ;i WITH PASSIVE
VENTING •
Total PW Costs: $1,813,200
In-situ air sparging is a remedial technology where· air is
introduced under pressure and below the water table to remove
dissolved voes. This alternative would also require monitoring
the groundwater both during and after remediation. Deed
restrictions would also be established to restrict the use of
contaminated groundwater associated with the Site. Passive
venting means that no vaaJum will be applied to the wells; VOCs
would be reduced through volatilization and anaerobic
biodegradation. GA-3 would permanently eliminate voes in
groundwater.
ALTERNATIVE GA-4: AIR .SPARGING WITH ACTIVE
VENTING
Total PW Costs: $1,928,000
In-situ air sparging is a remedial technology where air is
introduced under pressure and below the water table to remove
the dissolved voes. This alternative would require monitoring
the groundwater both during and after the remediation. Deed
restrictions would also be established to restrict the use of
contaminated groundwater associated with the Site. Active
venting means that a vaaJum would be placed on the wells to
actively remove the VOC vapors from the wells. GA-4 would
permanently eliminate voes in groundwater.
ALTERNATIVE GA-5: GROUNDWATER EXTRACTION/
TREATMENT BY CHEMICAL PRECIPITATION AND CARBON
ADSORPTION
Total PW Costs: $7,631,800
This al.ternative would involve installing eight shallow and a one
deep bedrock recovery well for the recovery and treatment of
contaminated groundwater. A piping system would also be
installed to transport the groundwater from the wells to a holding
tank and treatment system. Precipitatiori/filtration and carbon
adsorption would be used to. treat contaminated groundwater for
all site-related contaminants of concern. . The treated
groundwater would then be discharged to either a nearby
drainage ditch or to the local publicly-owned treatment works.
This .alternative would also involve long-term monitoring and
institutional controls. ·
ALTERNATIVE GA-6: GROUNDWATER
EXTRACTION/TREATMENT BY CHEMICAL PRECIPITATION,
AIR STRIPPING, AND CARBON ADSORPTION
Total PW Costs: $6,957,000
This alternative woulwlude all the components of Alternative.
GA-5, plus a low-pr.ray-aeration air stripper, The carbon
vessels used in this alternative would be smaller than those used
in Alternative GA-5. ~
ALTERNATIVES TO ADDRESS SOIL CONTAMINATION
ALTERNATIVE SA-1: NO ACTION
Total PW Costs: $55,640
By law, EPA is required to evaluate a "No Action" alternative to
serve as a basis against which other alternatives can be
compared. Under the No Action alternative, no remedial
response would be taken for the contaminated soil at the textile
facility. The contaminated soil would remain on-site as a
continuing source of groundwater contamination. Since no
restrictions would be placed on the future use of the site, the
potential exists for future on-site residents to be exposed to
contaminated groundwater. A Five-Year Review would be
ronducted every five years for a 30-year period to ensure that the ·
No Action altemative was protective of human health and the
environment; the present worth costs of the five-years reviews is
$55,640. '
ALTERNATIVE SA-2: LIMITED ACTION
Total PW Costs: $255,640
This limited action alternative would establish deed restrictions on
the textile facility to prohibit future uses of the site tha_t would
uncover or expose contaminated soil beneath the buildings and
pavement. The deed restrictions would also specify that the
property is on~ to be used for commercial or industrial purposes,
and is not suitable for residential or recreational purposes. The
existing buildings and pavement would be left in place. This
limited action remedy is readily implementable, but will require
the cooperation of local authorities. The present worth costs of
establishing deed restrictions is $200,000, while the present
worth costs of.the five-year reviews is $55,640.
ALTERNATIVE SA-3: CAPPING
Total PW Costs: $10,000,000
This alternative would require any areas of contaminated soil not
already covered to be capped with pavement. The existing
buildings would be left in place, and deed restrictions would be
established to prohibit future uses of the site to uncover or
expose contaminated soil beneath the buildings or any paved,
capped areas. This alternative would eliminate any direct contact
with contaminated soil and reduce the infiltration of contaminants
into the groundwater. This remedy could be implemented easily,
but the remedy would not effectively reduce
the volume or toxicity of the contaminated soil.
ALTERNATIVE SA-4: EXCAVA •. AND OFF-SITE
DISPOSAL .
Total PW Costs: $115,000,000
This alternative would involve excavating every area identified
with oontaminated soil, and transporting the soil off-site for
disposal. This alternative would require demolition of all existing
buildings and paved areas, and transporting the demolition
debris off-site to a disposal facility. This alternative would be
diffirult to implement due to the depth of the voe contamination
in the soil. Removing the contaminated soil would effectively
eliminate the source of groundwater contamination: however, the
cost of implementing this alternative is extremely high.
Furthermore, Burlington Industries has indicated that they have
plans to start manufacturing textiles at the facility.
ALTERNATIVE SA-5: SOIL VAPOR EXTRACTION
Total PW Costs: $1,143,000
This alternative would be used to remove voes from the
contaminated soil media by using a network of vapor extraction
wells. Groundwater would be .monitored before and after
treatment. The long-term monitoring of the groundwater at the
site would be established to ensure the remedy is achieving Its
objective. Deed restrictions would also be established to prohibit
the oonsumption of.oontaminated groundwater associated with
the Site.
CRITERIA FOR EVALUATING REMEDIAL ·
ALTERNATIVES
EPA's selection of the preferred cleanup alternative for the FCX-
Statesville Site (Operable Unit 3), as described in this Proposed
Plan, is the result of a comprehensive evaluation and screening
process. The Feasibility Study for Operable Unit 3 was
oonducted to identify'and analyze the alternatives considered for
addressing contamination. The Feasibility Study for Operable
Unit 3 describes, in detail, the alternatives considered, as well as
the process and criteria EPA used to narrow the list to potential
remedial alternatives to address the Site oontamination.
EPA always uses the following nine criteria to evaluate
alternatives identified in the Feasibility Study. While overall
protection of human health and the environment is the primary
objective of the remedial action, the remedial alternative selected
for the Site must achieve the best balance among the evaluation
criteria oonsidering the scope and relative degree of the
oontamination at the Site.
1. Overall protection of human health and the environment:
EPA assesses the degree to which each alternative
eliminates, reduces, or controls threats to public health and
the environment th.h treatment, engineering methods or
institutional control ·
2. Compliance with Applicable or Relevant and Appropriate
ReQuirements (ABARsl; The alternatives are evaluated for
compliance with all State and Federal environmental and
public health laws and requirements that apply or are relevant
and appropriate to the site conditions.
3. ,C.Q.S1; The benefits of implementing a particular remedial
alternative are weighed against the cost of implementation.
Cost include the capital (up-front) oost of implementing an
alternative over the long term, and the net present worth of
both capital and operation and maintenance costs.
4. lmplementabilrty: EPA considers the technical feasibility (e.g.,
how difficult the alternative is to construct and operate) and
administrative ease (e.g., the amount of coordination with
other government agencies that is needed) of a remedy,
including the availability of necessary materials and services.
5. Short-term effectiveness: The length of time needed to
implement each alternative is considered, and EPA assesses
the risks that may be posed to workers and nearby residents
during construction and implementation.
6. Long-term effectiveness: The alternatives are evaluated based
on their ability to maintain reliable protection of public health
and the environment over time once the remediation levels
have been met.
7. Recuction of contaminant toxicity, mobility, and volume: EPA
evaluates each alternative based on how it reduces (1) the
harmful nature of the contaminants; (2) their ability to move
through the environment: and (3) the volume or amount of
oontamination at the site.
8. State acceptance: EPA requests State comments on the
Remedial Investigation and Feasibility study reports, as well as
the Proposed Plan, and must take into oonsideration whethe.r
the State conrurs with, opposes, or has no comment on EPA's
preferred alternative.
9. Community acceptance: To ensure that the public has an
adequate opportunity to provide input, EPA holds a public
comment period and considers and responds to all comments
received from the oommunity prior to the final selection of a
remedial action.
EVALUATION OF ALTERNATIVES
The following summary profiles the performance of each
alternative in terms of the nine evaluation criteria noting how it
oompares to the other alternatives under oonsideration.
GROUN~WATER REM.TION
The following alternatives were subjected to detailed analysis for
migration control and remediation of the contaminated
groundwater:
Alternative 1: No Action
· Alternative 2: Limited Action
Alternative 3: Air Sparging with Passive Venting
Alternative 4: Air Sparging with Active Venting
Alternative 5: Groundwater Extraction/Treatment by Chemical
Predpitation and Carbon Adsorption
Alternative 6: Groundwater Extraction/Treatment by Chemical
Precipitation, Air Stripping, and Carbon Adsorption
.REMEDIATION
The following alternatives were subjected to detailed analysis for
alternatives to treat or control soil contamination:
Alternative SA-1 : No Action
Alternative SA-2: Limited Action
Alternative SA-3: Capping
Alternative SA-4: Excavation, Off-Site Disposal
Alternative SA-5: Soil Vapor Extraction
....... EPA'S PREFERRED ALTERNATIVE*******
After conducting a detailed analysis of all the feasible cleanup alternatives based on the criteria
described in the previous sections, EPA is proposing a comprehensive, multi-component cleanup plan
to address groundwater and soil contamination at the Site. The EPA preferred alternatives are:
Groundwater Alternative GA-4
Soil Alternative SA-5
Air Sparging with Active Venting
Cost= $1,928,000
Soil Vapor Extraction
Cost= $1,143,000
TOTAL COSTS= $3,071,000
Based on current information, these alternatives appear to provide the best balance of tradeoffs with . . .
respect to the nine criteria that EPA uses to evaluate alternatives. EPA believes the preferred
alternatives will satisfy the statutory requirements of Section 121 (b) of CERCLA, 42 USC 9621 (b), which
provides that the selected alternatives be protective of human health and the environment, comply with
ARARS, be cost effective, and utilize permanent solutions and treatments to the maximum extent
practicable. The NCDEHNR has reviewed and provided EPA with comments on the reports and data
from the Remedial Investigation and the Feasibility Study.
r;E-1
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Region 4
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Official Business
Penalty for Private Use $300
North Superlund Remedial Branch
Diane Barrett, Community Relations Coord.
McKenzie Mallary, Remedial Project Manager
'
EIPaso
Natural &as Campan
March 22, 1996
Mr. McKenzie Mallary,
Remedial Project Manager
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USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject:
Dear Ken,
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
•
P.O. Box 1492
El P:L<;O, TX 79978
Phone: [phone]
RECEIVED
MAR 2 5 1996
SUPERFUND SECTION
As we discussed in the conference call yesterday, attached is the most recent working schedule
showing RI, FS and Risk Assessment activities. I will be updating this schedule monthly and
including it with the status reports.
Please call me at [phone], or Ted LeJeune at [phone] if you need further
information.
Sincerely,
Nancy K. Prince, CGWP
Principal Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: N. Testerman, NCDEHNR
. ··, .....
March A ril Ma June
ID Task Name Duration Start Finish 2118 2125 313 3110 3117 3124 3131 4[/ 4114 4121 4128 515 5112 5119 5126 612 619 6116 6123
1 Phase IV 27d Mon 2(19(96 Tue 3/26(96
2 Install & Sample 20i,22 i, 27d Mon 2/19/96 Tue 3126196
3 Geoprobe sampling 5d Mon 2126196 Fri 3/1/96 • 4 Groundwater data review 5d Mon 411196 Fri 415196
5 Preparation of Draft R_I 39d Mon 2126196 Thu 4118196
6 Ecological Assessment 5d Mon 3125196 Fri 3/29196 -7 Figures 21d Mon 2126/96 Mon 3/25/96
8 PRP call to review figures 1d Thu 3128/96 Thu 3/28/96 m
9 Chapters 1-7 7d Fri 3122196 Mon 411196
10 Chapters 8-9 14d Mon 4/1/96 Thu 4118196
11 PRP Committee review Draft 5d Mon 4/22/96 Fri 4/26/96
12 PRP Committee Meeting 1d Wed 4124196 Wed 4124196
13 Revise Draft RI 5d Mon 4/29/96 Fri 5/3/96
14 Draft RI to EPA Od Fri 5/3/96 Fri 513196 ♦ 513
15
16 RA Od Mon 3/11/96 Mon 3/11/96
17 Site Visit 1d Mon 3111/96 Mon 3/11/96
18 Import data into GIS Key 3d Thu 3121196 Mon 3125196
19 Review Data 5d Mon 3118/96 Fri 3122196
20 Conference Call w/EPA 1d Thu 3121196 Thu 3121196
21 Assumptions Document 15d Mon 3118196 Fri 415196
22 PRP Review 4d Fri 3/29/96 Wed 413196 ml
23 EPA Review 5d Mon 4/8/96 Fri 4/12/96 -Task Summary .. 2# " Rolled Up Progress
Project: STATESV.MPP Progress Rolled Up Task Date: Fri 3/22/96
Milestone ♦ Rolled Up Milestone 0
Page 1
ID Task Name
24 Scoping Meeting With EPA
25 Human Health Assessment
26 Identify COPCs
27 Toxicity Assessment
28 Exposure Assessment
29 Risk Characterization
30 Risk Based Remedial Op
31 Ecological Risk Assessmen
32 Preliminary Data
33 Site Characterization
34 Site Visit
35 Toxicology/Exposure Ass
36 Soil Leaching Modeling
37 Risk Characterization
38 Summary & Conclusion
39 Uncertainties & Limitatio
40 Draft to PRP Committee
41 Review by PRP Committee
42 PRP Meeting
43 Revise Draft RA
44 Submit Draft to EPA
45
46
Project: STATESV.MPP
Date: Fri 3/22196
Duration
1d
41d
5d
10d
38d
5d
3d
35d
5d
13d
1d
18d
13d
23d
14d
10d
1d
10d
1d
5d
0d
Task
Progress
Milestone
Start Finish
Wed 4110196 Wed 4110196
Mon 3111196 Mon 516196
Mon 3125196 Fri 3129196
Mon 4122/96 Fri 513196
Mon 3/11/96 Wed 5/1/96
Mon 4/29/96 Fri 5/3/96
Thu 512/96 Mon 5/6/96
Mon 3/18196 Fri 513196
Mon 3/18/96 Fri 3122/96
Mon 4/8/96 Wed 4124/96
Thu 4/11/96 Thu 4111196
Mon 3/25/96 Wed 4117/96
Mon 3/25/96 Wed 4110196
Mon 4/1/96 Wed 5/1/96
Mon 4/15/96 Thu 5/2/96
Mon 4/22/96 Fri 5/3/96
Mon 5/6/96 Mon 5/6/96
Mon 5/6/96 Fri 5117196
Wed 518196 Wed 5/8/96
Mon 5/20/96 Fri 5124196
Fri 5/24/96 Fri 5/24/96
♦
...
March A ril Ma June
2/18 2/25 313 3/1D 311 3124 3/31 4(/ 4114 4121 4128 515 5112 5119 5126 612 619 6116 6123
;
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a
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Summary • Rolled Up Progress
Rolled Up Task
Rolled Up Milestone 0
Page 2
ID Task Name
47 FS
48 Pump Test
49 Install PW-1
50 Develop and Sample
51 Permit for water disposal I
52 Install piping for pump te I
53 Pumping test I
54 Pumping test data analys
55 Modeling & review
56 Determine ARARS
57 Draft List for PRP review
58 Treatment Technology Memo
59 Draft Treat. Eval Report
60 Final Treat Eva! Report
61 Tech Memo -Rem. Tech
62 Draft tech memo RAO
63 Fina! tech memo RAO
64 Draft FS
65 Review by PRP Committee
66 PRP Meeting
67 Revise FS
68 Draft FS to EPA
Project: STATESV.MPP
Date: Fri 3/22/96
Duration
0d
35d
5d
8d
3d
5d
1w
2w
10d
10d
1d
10d
10d
10d
10d
10d
5d
70d
10d
1d
5d
0d
Task
Progress
Milestone
Start
Mon 2126/96
Mon 3/4/96
Mon 3/4196
Mon 3/18/96
Wed 3127196
Mon 3/25196
Mon 4/1/96
Mon 4/8/96
Mon 4/15/96
Mon 3/25/96
Mon 4/15/96
Mon 4/29/96
Mon 5/13/96
Mon 5127196
Fri 5/17/96
Mon 5113196
Mon 5/27/96
Mon 3/4/96
Mon 6/10/96
Wed 6/12196
Mon 6124/96
Fri 6/28/96
♦
"'
r March A ril Ma June
Finish 2/18 2125 3/3 3/10 3/1 3/24 3/31 417 4/14 5/12 5/19 5/26 6/2 6/9 6/16 6/23
Mon 2126/96 ♦ 2/26
Fri 4/19/96
Fri 3/8/96
Wed 3127/96 ma
Fri 3/29/96 !ill
Fri 3/29/96 m-i
Fri 4/5/96 ~ Fri 4/19/96
Fri 4/26/96
Fri 4/5/96
Mon 4/15/96
Fri 5110/96
Fri 5/24/96
Fri 6/7/96
Thu 5/30/96
Fri 5/24/96 ~ Fri 5/31/96
Fri 617196
Fri 6/21/96
Wed 6/12196
Fri 6/28/96
Fri 6/28/96
Summary • • Rolled Up Progress
Rolled Up Task
Rolled Up Milestone 0
Page 3
I
I
February 23, 1996
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
•
P.O. Box 1492
El Paso, TX 79978
Phone: 9 I 5-541-2600
RECEIVED
FEB 2 9 1996
SUPERF'UMD SE:1.,1 .'.J ·
Subject: Study Plan for Conducting an Ecological Resource Characterization
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
Attached for your review, as we discussed on February 13, 1996, are two copies of the OU-3 Site
Group's revised proposal for the performance of an ecological assessment at the above referenced
Site. The revised proposal, Study Plan for Conducting an Ecological Resource Characterization of
the FCX-OU3 Superfund Site, Statesville, Nonh Carolina, is more appropriate to conditions at the
Site than the proposal that we submitted to you on February 2, 1996. We reached this conclusion
after comparing the Federal and Region IV screening values for freshwater with the surface water
samples taken at the Site. For your convenience, this information is contained in Table 1 of the
Study Plan.
You will note that substantially all the surface water sample results are significantly lower than the
Region IV screening levels. Accordingly, we believe that the type of survey proposed in the Study
Plan will provide us with the level of detail required for purposes of the RI/FS.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
Sincerely, ilOAUj k 9~~
Nancy K. Prince, CGWP
Principal Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: R. McKelveen, NCDEHNR
w/o attachments:
J. B. Ward, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801.111.1.3
•
T. LeJeune, Burlington
B. Hatcher, Burlington
B. Trexler, Aquaterra
J. Brothers, PEI
H. Mitchell, Jr., Beaunit Corporation
1 Introduction
•
Study Plan for Conducting An Ecological
Resource Characterization of the
FCX-003 Superfund Site,
Statesville, North Carolina
February 26, 1~96
Durin& January 1996, a document entitled Study Plan for ConductinQ a
Macromvertebrate Assessment of an Unnamed Tributary of Gregory Creek, Receiving
Non Point Source Surface Water Drainage from the FCX Statesville OU3 Superfund
Site, Statesville, North Carolina was provided to the United States Environmental
Protection Agency (EPA), Region IV for review and comment. Following submittal ·
of this document, the OU 3 potentially responsible parties (PRP) review committee
discovered additional information concemmg the process of ecological assessments
at Superfund sites.
Upon comparison of surface water analytical results from the FCX-Statesville
Superfund Site to Federal and Region IV EPA surface water screening values (see
Table 1) it was determined that a detailed macroinvertebrate assessment might not
be required for the site. With the exception of one sample containing
tetrachloroethylene, results for all compounds detected in surface water were below
established Federal screening values. Two additional samples exceeded Region IV
screening values. All three of these samples were collected from the same location.
Samples collected downstream of this location did not exceed either Federal or
Region IV screening values.
Based on this information, the PRP committee would like to submit this revised work
plan entitled Study Plan for Conducting an Ecological Resource Characterization of the
FCX-OU3 Superfund Site, Statesville, North Carolina to characterize the general
ecology of the site and its surrounding area. If the risk assessment later indicates the
likelihood of a significant threat to the health of organisms living in the impacted
surface water, a more detailed assessment of the stream organisms will be conducted
at that time.
Shealy Environmental Services, Inc. proposes to conduct an ecological resource
characterization for the FCX-OU3 Superfund Site, Statesville, Iredell County, North
Carolina in order to provide information on the ecological resources of the Site and
its surrounding area. The resource categories to be examined are: vegetation,
aquatic biota, wetlands, wildlife, and species of concern.
2 Methods
Investigative methods for establishing aquatic and terrestrial resource characteristics
will include a field reconnaissance survey, contact with local resources authorities and
compilations of existing information. The characterization will be limited to the area
withm a half-mile radius of the site. A description of characterization methods for
each resources category are given below.
•
2.1 Vegetation
The type, composition, location and general appearance of major vegetation species
will be documented during the field survey. United States Geological Survey
(USGS) quadrangle maps and any known site aerial photographs will be examined to
locate and map boundaries of each vegetation type that will be identified in the field.
2.2 Aquatic Biota
The physical condition of all streams and ponds within the study area will be
documented. Random observations of aquatic life made during the field
reconnaissance survey will be noted. State aquatic biologists will be contacted in
order to obtain any data available on fish and/or benthic macroinvertebrate
assessments performed in the study area.
2.3 Wetlands
Potential wetland resources will be identified within the study area by using available
USGS maps and aerial photographs. These areas will be verified during the field
reconnaissance survey. No jurisdictional delineations will be made.
2.4 Wildlife
The presence and current status of wildlife resources will be determined by
interviewing local wildlife agency personnel and by conducting a field reconnaissance
survey. Available wildlife habitats in the study area will be documented during the
reconnaissance.
2.5 Species of Concern
The presence and status of threatened, endangered, and special-concern species
and/or habitats critical to their survival will be documented. The major sources of
information will be field offices of the United States Fish and Wildlife Service and
the North Carolina Fish and Wildlife Department.
3 Report
A report will be prepared characterizing each of the five ecological resource
categories in the study area. The report will include all observations made during the
field reconnaissance survey. Techmcal documents used in support of the ecological
resource characterizations will be referenced.
Table 1: SURFACE \VATER VOLATJLE ORGANIC ANALYSIS RESULTS ,vrrn EPA FEDERAL ANO REGION IV SCREENING VALUES FOR FRE,5HWATER
(Concentrations in ug/L)
Federal Standards * Region IV Standards "* Surface Water Volatile Organic Ana!V!tis Results
Analyte Acute Chronic Acute Chronic SW-1 SW-1 SW-2 SW-4 SW-5
Criteria Criteria Criteria Criteria DUP
1.1 -Dicbloroethane
1.2 -Dichloroethane 113.000 20 000 11.800 2.000
cis -1.2 -Dichloroethvlene 0.1 I 670 340
trans -1-2 -Dichloroethvlene 13 500 1.350 17 J 16J
1.1 -Dichloroethvlene 11.600 3 030 303
l 2 -Dichloro e 23.000 5.700 5.250 525 110 120
2 -Buteoone
Acetone 6 4J
Carbon Disulfide
Chlorobenzene 250 50 1.950 195
Chlorofonn 28.900 l.240 2,890 289 . 6J
Chloromethane
Methvleoe Chloride 19.300 1930
Stvrene
Tettach[oroethvlene 5.280 840 528 84 0.31 0.4J l 240 1200
Toluene 17.500 1.750 175 0.4J 0.41
Trichloroethvlene 45.000 21.900 0.1 J O.lJ 0.2 J 720 750
Vinvl Cloride 140 43 J
Xvlenes (total)
• EPA 440/5-86-001, "Quality Criteria for Water 1986" wong with the latest draft update summary provided by the EPA
publications office on 2/12/96.
Region 4 Waste Management Division Freshwater Surface Water Screening Values for Hazardous W~ Sites.
J = Estimated Value
U .. Quatitation limit adjusted per data validation procedures
•
•
Table 1 (Conlinue.d}: SURFACE "WATER VOLATILE ORGANIC ANALYSIS RESULTS
\VITH EPA FEDERAL AND REGION IV SCREENING VALUES FOR FRESHWATER
(Conei!ntrations in ug/L)
Federal Standards * Regi-On IV Standards 0 Surface Water Volatile Organic Analvsis Results
Aoalyte Acute Chronic Acute Chronic SW-6 SW-6 SW-7 SW-8 SW-9 SW-10
Criteria Criteria Criteria Criteria DUP
1. L -Dichloroetliane 0.1 I
L.2 • Dichloroethane IL3.000 20.000 LL,800 2.000 0.3 I
cis -1.2 -Dichlorocthylene 180 190 1()() 17 34 59
trans -l.2 • Dichloroethvlene 13,500 1.350 lS I 11 I 3J I 3 2J
1-.1 -Dichloroethvlene 11.600 3.030 303 0.5 I
1.2 -Dichloronr~= 23.000 5.700 5.250 525 49 52 41 1 J 4 4J
2 • Butenone lU
Acetone 60U 9U 16 U
Carbon Disulfide
Chlorobenzene 250 50 1,950 195
Cblorofonn 28.900 1.240 2,890 289
Chloromethane
Methvlene Chloride 19 300 1930 8J 46 J
Stvrene
Tetrachloroethvlene 5.280 840 .528 84 52 36 100 5 10 64
Toluene 17 .500 1,750 175 IU
Trichloroethvleoe 45.000 21.900 300 330 140 16 35 58
Vinvl Cloride 44 51 14 12 15 12
Xvlenes ftotal)
• EPA 440/5-86-001, •Quality Criteria for Water 1986" along with the latest draft update summary provided by the EPA
publications office on 2112/96.
•• Region 4 Waste Management Division Freshwater Surface Water Screening Values for Hazardous Wasle Sites .
1 "" Estimated Value
U .. Quatitatioo limil adjusted per data validation procedures
•
M,;fl-24-95 09: 19 FROM: EPNG ENVIRONMENTAL AFFAIR ID: 915544 •
EIPastC1
Natural 6as Campem.1
May 23, 1995
Mr. McKenzie Mallary,
Remedial Proje<;t Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, UA 30365
Subject:
Dear Ken,
Request for Additional Investigation
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigatlon/Feasiblllty Study
•
P. 0. BOX 1402
EL PASO, T[)(hr, ·1~9-,u
PHONL: 91~)•t'l41 •:./ti00
PAGE 2
I have reviewed your May 10, 1995 request for additional groundwater sampling with the Operable
Unit Three (OIJ-3) Group.
The nu .. 1 Group proposes to perfonn Hydrocone sampling and to install additional groundwater
monitoring wells as described in the letter from Aquaterra dated May 22, 1995, a copy of which if
attached.
llydrocone sampling on the FCX property and monitoring wells A, B, C, D, E, F, G, and H arc
consistent with recommendations in the previously filed draft Preliminary Site Characteri1ation
Summary (PSCS) dated May 8, 1995. The Hydrocone sampling and monitoring wells I, J, K, and
L arc Aquaterra's proposed locations to address your desire for delineation of the groundwater
contamination nowing from the FCX property to the south. The OU-3 Group believes the
sampling recommended in the PSCS is consistent with the obligation of the OU-3 Group as
described in paragraph 1.3 of the February 25, 1994 Work Plan.
The O\l-3 Group does not agree with the statement in your May 10, I 995 letter that "VOC
groundwater contamination is migrating to the ... south or the Burlington Industries properly."
Based upon the PSCS, the OU-3 Group believes the current groundwater flow data indicates there
is a S1:paratc source and contaminant plume originating on the FCX property and flowing to the
south of that property. Therefore, the OU-3 Group does not believe that the groundwater sampling
proposed for south of the FCX property is properly an OU-3 obligation. Instead, the ()ll-3 Group
believes this sampling is an Operable Unit I (OU-I) obligation which is described in p,tragraph 1.3
of the Work. Piru1 as "remediation of impacted ground water at and downgradicnt of the FCX
facility, Ground water substances include pesticides and volatile organic compounds (VOCs)."
MR,._V-24-95 09 • 19 FROM= EPNG ENVIRONMENTAL AFFAIR ID, 915544 • •
However, the OU-3 Group has concluded that all parties, including the general public, would
benefit from expediting sampling and delineation activities in and around the FCX site. Therefore,
· the OU-3 Group will agree to install and sample the monitoring wells and sampling points south of
the FCX property as shown on the attached proposal from Aquaterra; however, this sampling work
will be undertaken with a reservation of rights. In the event the sampling confinns the opinion of
the OU-3 Group that groundwater contamination south of the FCX property is the result of a
release distinguishable from any release associated with the property now owned by Burlington
Industries, tl1c OU-3 Group may seek reimbursement for these expenditures.
Please review the sampling plan proposed by Aquaterra and advise the OU-3 Group of any
corrections EPA believes appropriate. The OU-3 Group will schedule sampling as soon as we have
EPA's comments on or concurrence with the sampling plan.
Please r.:;ill me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
Sincerely,
Lf'IOA-1.Af ;(~CA.,
Nancy K. Prince, CGWP
Principal Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
T. Hutchins, EPNG
J. 8. Ward, EPNG
J. Porter, Andrews & Kurth
G. House. BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801.Ill. l.3
R. McKelveen, NCDEHNR
T. l.cleune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, PEI
H. Mitchell, Jr., Beaunit Corporation
PAGE 3
M~Y-24-85 08:18 FROM, EPNG ENVIRONMENTAL AFFAIR ID, 815544 • •
A 1 '='"-EQUaT-rra· "'0 ""0 "·'" H<•oqu •• , •• .,
,~ liiiiiiii POST OrFICE POll 37579 • ~A.LEIGH, NC• 27627-7!.i'l!;I • (919t 1-l!}!I !l!!t17 • FAll C9l9J 859·0030
AGffEAT l.AKE~CIO:'.MICAL COJft'-OR.l.TION GOM,.ANY
May 23, 1995
Mr. McKenzie Mallary
Remedial Project Manager
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Reference: Response to May 10, 1995, Request for Additional
Ground Water Investigation ·
FCX-Statesville Superfund Site, Operable Unit 3
Statesville, North Carolina
Aquaterra Job No, 3107703
Dear Mr. Mallary:
In order to assist the United States Environmental Protection Agency, Reipon IV in
further characterizing the extent of volatile organic compounds (VOCs) m ground
water to the south of the Farmer's Cooperative Exchange (FCX) facility, the
Operable Unit 3 Group proposes to first sample shallow ~round water with a
I-iydrocone sampler at appr□JOmatcly 24 locations in the area indicated on Figure 1.
The samples will be analyzed for VOCs by method 8240 with a t}_ve gay_!urnaround.
The results of these analyses will be used to assist in choosing locations for
installation of shallow monitoring wells,
Soil and shallow ground water sampks will also be collected with the I-lydrncone
sampler from the vicinity of the southeastern corner of the FCX warehouse to
determine if a VOC source exists in this area (see Figure 1). These samples will also
be analyzed for VOCs by Method 8240 with a five day turnaround.
Additional monitoring wells will be Installed at the approximate locations I, J, K, L,
and M (see Figure 1). All of the shallow well bonngs will be advanced to auger
refusal in order to learn more about bedrock topography to the south of FCX. The
borings will be backfilled with bentonite until the desired screen depth is reached.
These wells will be installed during Phase Ill of the Remedial Invc5tigation field
activities along with proposed wells at locations A, B, C, D, E, F, G, and H. Newly
instulled wcll5 and perimeter wells specified in the May 8, 1995, Draft Preliminary Site
Chara,terization Summary will be sampled for Target Com/mund List (TCL) VOCs.
The stream located south the FCX facility will also be samp ed for TCL YOCs.
ENVIRONMENTAL Cc:ir,,islJL.1'ANTS
PAGE 4
M~~-24-95 09,20 FROM, EPNG ENVIRONMENTAL AFFAIR • ID, 915544
FCX-•. svillt: Supcrfunc.l Site
Opera\1lc lJnit 3
5HMI I
May 2}, 191)5
!'age 2
A Ul'l 1,;;;timntc for tl,c prnpo~,ad a$SCssment activities in the area south of FCX has
been ind11tlt:tl in App(,mlix A Ir you have any questions ur comments concerning
this matter, please contact Ms, Nancy Prince of El Paso Natural Gas Cornp,1ny at
(915) 541-28:19,
Si11ct:rcly,
AOUATFRRA, INC.
/J{~, {f , )~jc,-iJ
Slrnn,n A Myc:rs, P,G, 1
Remetlial Investigation Team Leader
Bryso11 D, Trcxkr, Jr, PhD,, P,G,
RJ/FS Program Marn•ger
510411/SAM/BDT/lct
PAGE 5
M~V-24-95 09,20 FROM, EPNG ENVIRONMENTAL AFFAIR •
I
/
.......
Ml ...
llvrt'ot
"' PIOJIOIN WIii IDollllr1 ,_,
i
....
11-17-1:1
r • IOU'
ID, 9155q4 •
0 ...
: I
. . . . ... _:;_ ,,
II i..
..
PAGE s
. M~Y-24-95 09,19 FROM: EPNG ENVIRONMENTAL AFFAIR ID, 815544 • •
r.::tEIPasa 13 Natural lia1 Ca11pa1111
Facsimile Cover Sheet
To: R. Md>('elveen
Company: NCDEHNR
Phone:
Fax: [phone]
From: Nancy Prince
Company: El Paso Natural Gas Company
Phone: [phone]
Fax: [phone]
Date: 5/24/95
Pages including this JI?
cover page:
Comments:
Any qusetions please call Kevin Sedlak at [phone]. Thank You
PAGE 1
R::r::
•
EIPaso
Natural 6as Compan4
•
RECEIVED
MAY L5199S
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: 915·541-2600
May IO, 1995
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: MONTI-IL Y STATUS REPORT NUMBER 22, APRIL, 1995
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study ~
Dear Ken,
This status report is being submitted in accordance with Section VII of the Administrative Order on
Consent (AOC) executed June 25, 1993 between USEPA Region IV, and Burlington Industries,
Inc. (Burlington) and El Paso Natural Gas Company (EPNG).
I.
II.
111.
Actions taken toward achieving compliance with the Consent Order during the previous
month:
1. Aquaterra continued preparation of the Draft Preliminary Site Characterization
Summary (PSCS) for submittal to EPA May 8, 1995.
2. Aquaterra collected water level measurements from all site monitoring wells and
confirmatory samples from two suspected source areas on April 10, 1995.
Results of sampling and tests and all other data received by Respondents during the course
of the work:
I. No new data was received in April, 1995.
Plans and procedures completed under the Work Plan during the previous month:
I. No plans or procedures were completed during April, I 995.
• •
IV. Actions, data, and plans scheduled for the next month, and other information relating to the
progress of the work:
l. Aquaterra plans to complete the draft PSCS for submission to EPA on May 8,
1995.
V. Percentage of completion, unresolved delays encountered or anticipated, efforts made to
mitigate delays:
1. Phase I sampling activities are 99% complete as of March 31, 1995.
Phase II activities are 96% complete as of March 31, 1995.
VI. Other items of interest not directly related to AOC activities:
1. None during April, 1995.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
Sincerely,
'fl~c-yl:~
Nancy K. Prince, CGWP
Principal Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
T. Hutchins, EPNG
J. B. Ward, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801. III. 2
R. McKelveen, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, PEI
H. Mitchell, Jr., Beaunit Corporation
I •
EIPasa
Natural &as Compan4
•
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: 9 i 5-541-2600
November 8, 1994
CEIV!!:D
Nov 15 1994
~S_U_P_E_R~FU:.:N::;D:__-SEc ,n .. /
Mr. McKenzie Mallary,
Remedial Project Manager
-!.'E!!.}
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: MONTHLY STATUS REPORT NUMBER 16-0ctober, 1994
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
This status report is being submitted in accordance with Section VII of the Administrative Order on
Consent (AOC) executed June 25, 1993 between USEPA Region IV, and Burlington Industries.
Inc. (Burlington) and El Paso Natural Gas Company (EPNG).
I. Actions taken toward achieving compliance with the Consent Order during the previous
month:
I. Groundwater sampling of 41 monitoring wells and the Carnation production well
was completed.
II. Results of sampling and tests and all other data received by Respondents during the course
of the work:
III.
1. A portion of the analytical results from the Phase II soil samples collected during
well installations have been received and are undergoing QA/QC review. These
results will be sent to U.S. EPA following this review.
Plans and procedures completed under the Work Plan during the previous month:
1. A map of proposed Phase II soil sampling locations is being prepared to assist in the
planning of Phase II soil sampling field activities. This map will be forwarded to
U.S. EPA for review as soon as it is complete.
I • •
IV. Actions, data, and plans scheduled for the next month, and other information relating to the
progress of the work:
I. Phase II soil sampling will continue in November.
V. Percentage of completion, unresolved delays encountered or anticipated, efforts made to
mitigate delays:
I. Phase I sampling activities are 92 % complete as of October 31, 1994.
Phase II activities are 60% complete as of October 31, 1994.
VI. Other items of interest not directly related to AOC activities:
I. None during October, 1994.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
Sincerely,
~QA_<--<-/ ~Cz
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801.IIl.2
R. McKelveen, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
H. Mitchell, Jr., Beaunit Corporation
MEMORANDUM
SUBJECT: In-house Remedial Investigation and Feasibility
Study ( RI /FS) at the FCX, Inc. ,_ Statesville Site
Statesville, North Carolina
FROM: McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
TO: Bill Bakey, ESD
Winston Smith, ATPD
Bernie Hayes, GWTU
Elmer Akin, Risk Assessment
Suzanne Durham, CRC
Marcia Owens, ORC
Chuck Pietrosewicz, ATSDR
Grover Nicholson, NCDEHNR
Hagen Thomp_son, OPA
PURPOSE: The purpose of this memorandum is to inform you
that an In-house RI/FS has been initiated by EPA-Region IV
for the FCX, Inc. -Statesville site in Statesville, North
Carolina. I request the help of-you and your staff in
planning the work, performing the Remedial Investigation and
Feasibility Study, and preparing the actual reports. The
ARCS contractor Roy S. Weston has been tasked to provide
support for some of the work.
BACKGROUND: The Farmers Cooperative Exchange, Inc. (FCX)
repackaged and distributed various pesticides at the site
from about 1940 until the late 1960s. According to a former
_plant manager, approximately 5,000-10,000 pounds of
pesticides were buried in a trench under what is now the FCX,
Inc. warehouse. These pesticides reportedly included DDT,
TDE, Lindane, and Chlordane.
On May 6 and 7, 1986, a site inspection was performed by the
North Carolina Department of Environmental Health and Natural
Resources (NCDEHNR). Analyses of soil and groundwater
samples indicated contamination with DDT, Lindane, and
Chlordane.
I. • •
-2-
OBJECTIVE: A tentative timeline has been developed for the
start of the RI/FS process with the following dates:
TASK
Initial Scoping meeting
Draft Work Plans
Fieldwork
RI Report
DATE
November-December 1990
January 1991
March 1991
July-August 1991
I will be contacting you soon regarding: 1) the initial
scoping meeting and 2) any support your staff may be able to
provide. Please contact me at [phone] if you have any
questions regarding this matter.
•
EIPasa
Natural Gas Compan4
•
P. 0. SOX 1-192
EL PASO. TEX;\S 79978
PHONE: [phone]
October 7, 1994
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: MONTHLY STATUS REPORT NUMBER 15-September, 1994
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
This status report is being submitted in accordance with Section VII of the Administrative Order on
Consent (AOC) executed June 25, 1993 between USEPA Region IV, and Burlington Industries,
Inc. (Burlington) and El Paso Natural Gas Company (EPNG).
I. Actions taken toward achieving compliance with the Consent Order during the previous
month:
I. The last three phase II monitoring wells (2 shallow and 1 intermediate) have been
installed inside the textile manufacturing facility. Water levels were measured in all
monitoring wells on September 27, 1994, and ground water sampling of 41
monitoring wells and the Carnation well began on September 28, 1994. An
updated schedule for field activities is being sent as Figure 1 under separate cover.
2. Registered land surveyors completed the survey of the 23 new wells, the sediment
and surface water sampling locations, and the refuse pile sampling location north of
the textile plant.
II. Results of sampling and tests and all other data received by Respondents during the course
of the work:
I. The remainder of Phase I soil analytical results have been received and are under
QA/QC review. A portion of the results have been reviewed and are being sent to
U.S. EPA under separate cover.
•
III.
IV.
V.
• •
2. A portion of the results for soil samples collected during well installations have been
received and are undergoing QA/Q<:, review. These results will be sent to U.S.
EPA following this review.
Plans and procedures completed under the Work Plan during the previous month:
1. No plans or procedures were prepared during the previous month.
Actions, data, and plans scheduled for the next month, and other information relating to the
progress of the work:
I. Sampling of 41 monitoring wells and the Carnation supply well will be completed
during October.
2. As described in the Work Plan, the Site Group and Aquaterra will review the
presently available Phase I soil and groundwater data and propose Phase II soil
sampling locations to U.S. EPA during October. Sampling is planned as soon as
U.S. EPA and the Site Group are in agreement on the locations and analytes.
Percentage of completion, unresolved delays encountered or anticipated, efforts made to
mitigate delays:
I. Phase I sampling activities are 92% complete as of August 31, 1994.
Phase II activities are 50% complete as of August 31, 1994.
2. Drilling in the textile plant took longer than anticipated because of problems with
moving the rig into the rooms with low ceilings.
VI. Other items of interest not directly related to AOC activities:
I. None during September, 1994.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
~-~ -/(r;;;v:,._"-'-
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
•
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801.IIl.2
•
R. McKelveen, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
H. Mitchell, Jr., Beaunit Corporation
tv1ASTER SCHEDJLE For FCX Statesville Field Work
•
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• •
EIPaso
Natural &as Compan-.
P. 0. BOX 1492
El PASO. TEXAS 79978
PHONE· 915-541-2600 -----RECf'"·ti,~ ,'1, \ _ .... ~ 1,,,.v
September 9,1994 SEP 1 Z 1994
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: MONTHLY STATUS REPORT NUMBER 14 -August, 1994
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
This status report is being submitted in accordance with Section VII of the Administrative Order on
Consent (AOC) executed June 25, 1993 between USEPA Region IV, and Burlington Industries,
Inc. (Burlington) and El Paso Natural Gas Company (EPNG).
I. Actions taken toward achieving compliance with the Consent Order during the previous
month:
I. All Phase II monitoring wells except the three wells (two shallow and one
intermediate) planned for inside the Burlington Industries building were installed.
The interior wells are in the process of being installed. An updated schedule for
field activities is included as Figure 1.
2. The door-to-door survey to determine ground water use is complete.
II. Results of sampling and tests and all other data received by Respondents during the course
of the work:
1. The majority of Phase I soil analytical results have been received and are under
QA/QC review. A portion of the results have been reviewed and are being sent to
U.S. EPA under separate cover.
2. A portion of the results for soil samples collected during well installations have been
received and are undergoing QA/QC review. These results will be sent to U.S.
EPA following this review.
• •
III. Plans and procedures completed under the Work Plan during the previous month:
1. No plans or procedures were prepared during the previous month.
IV. Actions, data, and plans scheduled for the next month, and other information relating to the
progress of the work:
1. Phase II installation of monitoring wells will be completed in September.
2. The new monitoring wells will be surveyed, water level elevations in all monitoring
wells will be measured, and all new and existing wells are anticipated to be sampled
during September.
V. Perceniage of completion, unresolved delays encountered or anticipated, efforts made to
mitigate delays:
1. Phase I sampling activities are 90% complete as of August 31, 1994.
Phase II activities are 35 % complete as of August 31, 1994.
2. Difficult conditions were encountered during coring. In the first wells friable felsic
seams were encountered that washed out, causing the rod to break in the hole. The
remaining wells were drilled as dual holes, with a separate hole being drilled for
coring immediately adjacent to the well borehole. This resulted in the coring taking
approximately two weeks longer than anticipated.
The drill rig encountered problems with access inside the building which resulted in
the installation of the three final wells taking three weeks longer than anticipated.
We have experienced delays in receipt of computerized data from the lab. The lab
has assigned additional personnel to data entry to accommodate our requirements.
To date these problems have not resulted in a delay of the schedule.
VI. Other items of interest not directly related to AOC activities:
1. None during August, 1994.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions or
comments.
~i2Ml-'f ~Q~c,_
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
i
'. •
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
D. Sparrow, Beaunit Fabrics Corp.
file: 8801.III.2
•
R. McKelveen, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
H. Mitchell, Jr., Beaunit Corporation
MASTER SCHEDULE For FCX Statesville Field Work
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-----------------------------·-
•
' •
EIPasa
Natural 6a. Campan1.1
June 16, 1994
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
•
P. 0. BOX 1492
EL PASO. TEXAS 79978
PHONE: [phone]
RECEIVED \
JUN 2 2 1994
.SUPEF!FUND secr10~~1
Subject: tl1Hi\SE-J-SOIL-SAMPI;ING;JRevision to Work Plan
FCX -Superfund Site, Statesville, North Carolina
ou;J:RemeilialJily)!Stigatioii/Feasiliility.Stiiily
Dear Ken,
As per our conversation on June 13, the Group would like to propose the following minor
modifications to Phase I soil sampling activities outlined in the Work Plan.
Because the soil gas survey indicated a larger area of concern than had been anticipated, we
propose to use the Phase I soil sampling to begin delineation, and limit the number of samples
used to confirm soil gas results. We are not proposing the change the total number of samples,
only the arrangement of the sampling locations.
I. As indicated in the RI/FS work plan, soil samples will be collected from each study area
in soil containing the highest level of contamination as indicated by the soil gas survey,
OVA screening, or visible staining. One of these samples will be analyzed for
TCL/TAL.
2. A grid (see Figure 1, being faxed tc y.;u under s.:-~"u.tc cov~~ by Aquaterra) which
includes the following study areas was laid out over the site:
Pollution Control Units (#1 and #2)
Former Rail Spur and Machine Shops
Former Dry Cleaning Machine
Storm Drain and Sanitary Sewer
Existing Maintenance Shop
At each of the indicated locations, 2 soil samples will be collected and analyzed for TCL
voes and svocs.
• •
The soil sampling was begun on June 6. Soil samples have been collected from the Southern
Railway Line and the Refuse Pile study areas. The remainder of the soil samples will be
collected starting June 20, 1994.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions
or comments.
Sincerely,
7{ewu;~co
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
file: 8801.ill.4.1
R.McElveen,NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEI
,, · .
•
•
;
" •
EIPaso
Natural 6as Compan4
May 25, 1994
•
F(~,~E.a" cO
JUN 1 3 1994
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: 915•541•2600
Mr. McKenzie Mallary,
Remedial Project Manager SUPERFUND SECTION
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject:
Dear Ken,
FHASE-1-SOII:,GAS-AND-SOII;-SAMPI;ING;-Revision-to-Work-:FJanJ
FCX -Superfund Site, Statesville, North Carolina
10U-3-Remedial-lnvestigation/Feiisi6ility_Stuily7
As per our conversation on May 24, the Group would like to propose the following minor
modifications to Phase I soil gas and soil sampling activities outlined in the Work Plan. It is
our belief that these changes will not adversly impact the quality of data accumulated during
Phase I activities, or conclusions about the extent of contamination drawn from these activities.
L. Analyze a maximum of 3 soil gas samples per location:
According to the Work Plan, samples are collected by the RECON van at two foot
intervals from surface to 15 feet in depth, all samples are screened with an FID (flame
ionization detector) and GC analysis is run on soil gas from all intervals which indicated
VOCs above 10 ppm on the FID. More samples have been above this level than were
originally anticipated. At many locations, if one or two intervals have had high FID
readings, then most of the intervals have also had high readings.
The Group suggests therefore that we only run soil gas on intervals with the three highest
FID readings at each location. We believe that since the soil gas survey will be followed
by soil analysis at an EPA approved laboratory, this change will not compromise the
quality of our data.
2-,. · Do not analyze soil gas samples along the railroad:
The railroad area is not going to be accessible to the RECON van. The Work Plan calls
for a total of 10 soil samples to be analyzed in the laboratory, with the samples selected
based upon RECON analyses. The Group proposes to select these samples based on the
following criteria instead: I) locations near potential sources such as surface drainages
• •
off the BI property, 2) FID screening, and 3) staining or odor.
3.,. Use a drill rig to collect soil samples:
The Work Plan indicated that soil samples for laboratory analysis would be collected with
the RECON van. The Group proposes to use a hollow stem auger drill rig instead
because the rig is able to collect larger samples much more rapidly. QA/QC procedures
outlined in the Work Plan for sample collection during monitoring well drilling will be
followed.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions
or comments.
Sincerely,
'-ft~ I! O~cz
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
file: 8801
R. McElveen, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
•
EIPaso
Natural &as Compan4
February 25, 1994
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: FINAL PLANNING OOCUMENTS
•
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: 915,541-2600
Enclosed are the final RI/FS planning documents for OU-3, FCX-Superfund Site, in accordance
with the Admininstrative Order By Consent, EPA Docket No. 93-07-C, signed June 25, 1993.
As per our conversation on February I 8, 1994, 4 copies (3 bound and I unbound) of each of
the following deliverables are enclosed:
RI/FS Work Plan
Sampling and Analysis Plan: Field Sampling Plan and Quality Assurance Project Plan
Site Health and Safety Plan
These documents have been revised to incorporate comments received by the PRP group on
January 27, 1994, in accordance with our discussion with you on February 1, 1994.
Two sets of comments were also received on February 22, 1994. We have attempted to respond
to the major issues outlined in the U.S. EPA risk review comments.
The Health and Safety Plan was being reproduced when the comments from the North Carolina
Superfund Toxicologist were received. We will take these comments into consideration as field
work is conducted throughout the RI/FS.
These documents were prepared by Aquaterra Inc., Raleigh, North Carolina, at the direction of
the PRP group: El Paso Natural Gas Company, and Burlington Industries, Inc. We anticipate
that we have favorably addressed your comments and look forward to the upcoming field season.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions.
•
Sincerely,
Y{ wit&cj ;:: 9/UA·C-(_
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG (w/o attachment)
H. Van, EPNG (w/o attachment)
T. Wright, EPNG
J. Porter, Andrews & Kurth
file: 8801.III.4. l
•
CR-:-McElxeen,_NCDEHNR7
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
G. House, BPMHL
• MEMORANDUM
April 11, 1994
TO: DISTRIBUTION
FROM: Nancy K. Prince
OU-3 Project Coordinator
SUBJECT: REPLACEMENT PAGES FOR RI/FS PLANNING DOCUMENTS
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
The enclosed pages indicate that the documents submitted in February by the OU-3 Site Group
are the final planning documents for the RI/FS. Please replace the appropriate pages in your
copy of the work plan.
Call me at [phone], or Sharon Myers at [phone] if you have any questions about
these changes. ___
DISTRIBUTION:
K. Mallary, EPA (4 copies)
G. Odegard, EPNG (w/o encl)
H. Van, EPNG (w/o encl)
T. Wright, EPNG (I)
J. Porter, Andrews & Kurth(!)
G. House, BPMH & L (I)
file: 8801.III.4.1
/ ) ' _/ /_,;,,; '\ • i /":) C/cP"-u_
R. McElveen,-NCDEHNR (1)
T. LeJeune, Burlington (1)
B. Hatcher, Burlington ( 1)
D. Duncklee, Aquaterra (w/o encl)
N. Tyner, BE! (I)
FM-10-00QJA
MEMORANDUM
To:
From:
RE:
April 12, 1994
File
Randy McElveen
Environmental Engineer
NC Superfund
Conference Call
(RI7.FJDField Work and Public Meeting
FCX Statesville OU #3, Burlington Property
NCD 095 458 527
Statesville, Iredell County, NC
Ms. Nancy Prince the PRPs committee representative set up a
conference call with EPA, Ken Mallary, NC Superfund, Jack Butler &
Randy McElveen, PRPs contractor, Sherron Myers, and A Burlington
Ind. representative, Ted Lejeune at 10: oo Am Tuesday April 12,
1994. It was determined during the conference call that
groundwater, surface water and sediment sampling for the RI/FS
would begin the day following the kick off meeting for public
comment which was tentatively scheduled for Monday April 25, 1994.
It was also determined that the Recon Van would tentatively be
available on the week of May 2 to begin the soil gas survey at the
Site. The soil and air sampling results from the Friends residence
were also discussed briefly (see the memo to file dated April 5,
1994.) The PRPs Committee representative Nancy Prince will also be
providing a summary of this conference call with the names of those
in attendance.
cc: Jack Butler, NC Superfund Section
f
EIPaso
Natural Eias Campam.1
April 8, 1994
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
P. 0. BOX 1492
EL PASO. TEXAS 79978
PHONE: [phone]
RECEIVED \
APR 111994
SUPERF~ND SECTION I
Subject: 'MONTHLY~ST.ATUS:REP-OR!f NUMBER 9 -March, 1994
FCX -Superfund Site, Statesville, North Carolina
OU-3 RemeiliaJ:Investigation/Feasiliility_Sfii_dy;
Dear Ken,
This status report is being submitted in accordance with Section VII of the Administrative Order
on Consent (AOC) executed June 25, 1993 between USEPA Region IV, and Burlington
Industries, Inc. (Burlington) and El Paso Natural Gas Company (EPNG).
Actions taken toward achieving compliance with the Consent Order during the previous month:
l. Pending approval of the RI/FS Work Plan by the USEPA, no actions were taken during
the previous month.
Results of sampling and tests and all other data received by Respondents during the course of
the work:
l. Pending approval of the Rl/FS Work Plan by the USEPA, no data sets were generated
or received during the previous month.
Plans and procedures completed under the Work Plan during the previous month:
l. Pending approval of the RI/FS Work Plan by the USEPA, no plans or procedures were
prepared during the previous month.
Actions, data, and plans scheduled for the next month, and other information relating to the
progress of the work:
1. In anticipation of approval of the RI/FS Work Plan by the USEPA, Aquaterra will begin
coordination activities so that sampling may begin as soon as possible.
Percentage of completion. unresolved delays encountered or anticipated. efforts made to mitigate
delays:
I. The OU-3 RI/FS project is essentially 8 percent complete as of March 31, 1994. No
project delays have occurred or are anticipated.
Other items of interest not directly related to AOC activities:
1. Aquaterra personnel accompanied representatives from North Carolina State Superfund
and Iredell County Health Department to residences immediately north of the site on
March 8 and 9, 1994. This visit was to collect air and surface soil samples to investigate
concerns expressed by previous residents. The team reported that they did not see any
evidence of contamination.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions
or comments.
Sincerely,
fl {faA Uj ~ E? /V~c__Q__
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
G. House, BPMH & L
file: 880 I. III. 2
[R-:::McK~l\'.een,_t-l"CDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
State of North cAlina
Department of ~ironment,
Health an·d Natural ·Resources'
Division of sO\icl Waste Ma11i/geme11t ·
.-'. ,; ' ...
James B. Hurit, Jr., G~vernor
Jonathan B. Howes, Secretary
Mr. Ken Mallary
US EPA Region IV
February 3, •· 1994
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Draft Health and Safety Plan
(Remedial Inv:es.fTga.tion7F~asiniYity_Study_(Ril.FS)7
[FCX_Stat~.§..~f11e7Site, Operable Unit #3, Groundwater
.and Soils at Burlington Industries
Statesville, Iredell County, NC
NCO 095 4511 527
Dear Mr. Mallary:
1 ,
The Draft Health and Safety Plan for the RI/FS at the FCX
Statesville site, Operable Unit #3: Burlington Industries property,
located in Statesville, North Carolina has been received and
reviewed by the North Carolina Superfund Section. Attached please
find the comments offered by a Superfund Toxicologist.
If you have any questions or comments, please do not hesitate
to contact Dave Lilley or me at [phone].
Attachment
Sincerely,
~\J~,fJvt ml
Randy Mc~
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
PO Box 27687. Raleigh. North Carolina 276 I 1-7687 Telephone 919-733-<1996 FAX 919-733-~8 IO
An Equal Opportunity /\ffirmotive Action Employer 5(/Yo recycled/ 10'h post-consumer poper
TO:
FROM:
RE:
•
Randy\McElveen
)
David Lilley
• January 28, 1994
Comments prepared on the Draft Site Specific Health and
Safety Plan for FCX Statesville, Operable Unit 3,
Statesville, NC ~
J After reviewing the above mentioned document,
following comments:
I offer the·
1. Page 11: Chemicals cannot be identified with the proposed
instrumentation, therefore, a concentration expressed as a
volume to volume ratio such as ppm is inappropriate. The
recommended term is "meter units" (mu).
2. Page 11: The proposed air monitoring equipment cannot
identify which of these chemicals an individual is being
exposed to at any particular time. Some of the chemicals
(such as chloroform and lindane) have inadequate warning
properties. There is no chemical cartridge that can protect
an individual from all the chemicals found on this site.
Therefore, cartridge respirators are not recommended for use
on this site.
3. Page 12, second paragraph: There is no s'uch thing as no risk.
If appropriate, the risk may be characterized as minimal.
4. Page 14, first paragraph: A "dust filter" is a respirator and
needs to be treated as such. The parameters used to determine
when a dust filter will be used must be defined.
5. Page 14, Levels Band C protection: How will goggles be worn
with full face respirators?
6. Page 15: Will hearing protection be required while drilling?
On page 15 it is stated hard hats must be worn during
excavation activities, but on page 13 it is stated no
excavation activities are planned for the site.
7. Page 16, potential upgrade to level C: see comment 2.
8. Page 20: Where will the eyewash station be located?
9. The information on Table 2 does not provide the information
necessary for determining the hazards associated with
operations to be conducted at the site and is meaningless in
the context of a health and safety plan. Most of the
information listed under the heading "health standards" are
not health standards.
DL/dl/wpcommen.doc/23
•
•
EIPaso
Natural Gas Compam,1
December 16, 1993
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: DRAFr PLANNING DOCUMENTS
•
FCX -Superfund Site, Statesville, North Carolina
OU-3 Remedial Investigation/Feasibility Study
Dear Ken,
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: [phone]
RECEIVED
DEC 2 8 1993
SUPERFUND SECTION
Enclosed are the Rl/FS draft planning documents for OU-3, FCX-Superfund Site, in accordance
with the Admininstrative Order By Consent, EPA Docket No. 93-07-C, signed June 25, 1993.
As per our conversation on December 14, I 993, instead of 15 copies of these documents
specified in the AOC, 7 copies (6 bound and I unbound) of each of the following deliverables
are enclosed:
RI/FS Work Plan
Sampling and Analysis Plan, bound separately as:
Field Sampling Plan and
Quality Assurance Project Plan
Site Health and Safety Plan
These documents were prepared by Aquaterra Inc., Raleigh, North Carolina, at the direction of
the PRP group: El Paso Natural Gas Company, and Burlington Industries, Inc. We look
forward to receiving your comments.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions.
Sincerely,
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
•
'
•
NKP/nkp
cc: G. Odegard, EPNG (w/o attachment)
H. Van, EPNG (w/o attachment)
T. Wright, EPNG
J. Porter, Andrews & Kurth
file: 8801.III.4. l
•
B. Nicholson, NCDEHNR (w/o attachment)
T. LeJ eune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEi
G. House, Brooks, Pierce
" •
EIPasa
Natural 6as Compan4
October 20, 1993
Mr. McKenzie Mallary,
Remedial Project Manager
USEPA Region IV Waste Management Div.
345 Courtland Street, NE
Atlanta, GA 30365
Subject: AUTHORIZATION TO PROCEED
•
(FCX1 -Superfund Site, •Statesville'; North Carolina
OU-3 /Remedial.lnv.estigation/Feasibility_Study:::)
Dear Ken,
P. 0. BOX 1492
EL PASO, TEXAS 79978
PHONE: 915·541 ·2600
This is to acknowledge receipt on October 18, 1993 of your letter approving Aquaterra
· Environmental Consultants as the contractor for the Operable Unit Three Remedial
Investigation/Feasibility Study at the FCX-Statesville Superfund Site.
This is also to confirm that the date of receipt of this letter of authorization to proceed is date
"x" of the Consent Order, and that the RI/FS Work Plan, Field Sampling and Analysis Plan,
Quality Assurance Project Plan, and Health and Safety Plan will be due to EPA and the State
on Friday, December 17, 1993.
As noted in my September 2, 1993 Jetter, I will be serving as Project Coordinator, Operable
Unit Three activities. Please address correspondence regarding this project to me.
Please call me at [phone], or Ted LeJeune at [phone] if you have any questions
or comments.
Sincerely,
Nancy K. Prince
Senior Environmental Scientist
Environmental Affairs Department
OU-3 Project Coordinator
•
NKP/nkp
cc: G. Odegard, EPNG
H. Van, EPNG
T. Wright, EPNG
J. Porter, Andrews & Kurth
file: 8801
•
B. Nicholson, NCDEHNR
T. LeJeune, Burlington
B. Hatcher, Burlington
D. Duncklee, Aquaterra
N. Tyner, BEI
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
OCT 1 3 1993
4WD-NSRB
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
Mr. Theodore H. LeJeune, P.E.
Burlington Industries, Inc.
P.O. Box 21207
Greensboro, NC 27420
Dear Mr. LeJeune:
ijtVIEOW~U
OCT 18 1993
SUPERfflijllSEtrJON
The purpose of this letter is to approve Aquaterra Environmental Consultants as the contractor for the Operable Unit Three Remedial Investigation/Feasibility Study at the FCX-Statesville Superfund Site located in Statesville, North Carolina. This letter, therefore, represents the authorization to proceed, as discussed in Section VII of the Consent Order. As the RI/FS contractor, Aquaterra will be responsible for performing all RI/FS activities, as outlined in the Consent Order and Statement of Work. Aquaterra will have 60 calendar days to submit an RI/FS Work Plan, Field Sampling and Analysis Plan, Quality Assurance Project Plan, and Health and Safety Plan to EPA and the State. Please contact me at [phone] if you have any questions regarding this matter.
Sincerely,
WGtlffev~ M,»,,_,rzr
McKenzie Mallary
Remedial Project Manager
cc: Randy McElveen, NCDEHNR
Nancy Prince, EPNG
Sharon Myers, Aquaterra
Nell Tyner, BEI
Printed on Recycled Paper
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
· 512 North Salisbury Street• Raleigh, North Carolina 27604
James 8. Hunt, Jr., Governor Division of Solid Waste Management
Telephone [phone]
Jonathan 8. Howes, Secreta,y
July 7, 1993
Mr. Michael Townsend
Remedial Project Manager
North Superfund Remedial Branch
345 Courtland street, NE
Atlanta, Georgia 30365
RE: Comments on Remedial Investigation/Feasibility Study and Draft
Record. of Decision (ROD)
Operable Unit #1, Groundwater
FCX Washington Site
NCD 981 475 932
Dear Mr. Townsend:
The Division of Environmental Management (DEM) has completed
the review of the subject documents and offers the following
comment.
1. Alternative 3 includes groundwater pumping, on-site
treatment and discharge to surface waters of Kennedy
Creek. As you know a NPDES permit is required for the
treated effluent to be discharged to Kennedy creek. The
Water Quality Section of DEM has also noted that
treatment or removal of contaminated sediments in the
Mount Pleasant Creek and drainage ditches and the
contaminated soil in the wetlands requires a 401
certification· and notification to the Corps of Engineers
before actual treatment and/or removal can begin.
If you have any questions or comments, please do not hesitate
to contact us at [phone].
Sincerely,~
"YI). t: _Arf\e_ ,
k~ndy McElveen
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
PO Box 27687, Raleigh, Nonh Carolina 27611-7687 Telephone 9!9-733-4984 F.::x # 919-733-0513
An Equal Oppom1nity Affirmative /\ction Employer
:i
. , ..
State of Nortt-A,rolina
Department -~vironment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes. Secretary
A Preston Howard, Jr., P. E., Director DEHNR.
May 24, 1993
M E M O R A N D U M
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: ~
1
A. Preston Howard, Jr .i,l ~
SUBJECT: FCX-Washington NPL Site
RI/FS
Beaufort County
Project #93-06
The Division of Environmental
the review of the subject document
comments and recommendations.
Water Quality
Management
and offers
has
the
completed
following
The Draft Remedial Investigation proposes several
alternatives to the treatment or removal of the contaminated
sediments in the Mount Pleasant Creek and drainage ditches and
the contaminated soils in the wetlands. The treatment and/ or
removal of this soil will require a 401 certification and also
notification to the Corps of Engineers· before actual treatment
and/or removal can begin.
Groundwater Section
It should be noted that many of the contaminants of concern
are not specifically addressed in NCAC 2L and are therefore not
permitted in detectable concentrations in groundwater. It may
be necessary for DEM to establish acceptable groundwater
remediation levels for these contaminants prior to any corrective
action taking place so that the goals of the groundwater
remediation can be clearly defined.
Air Quality
The Toxics Protection Unit of the Air Quality Section has
reviewed the Draft RI/FS for the FCX-Washington Site. Enclosed
is a copy of their comments.
APH/sbp/FCX.SWM
cc: Alan Klimek
Raleigh Reg. Office
Groundwater Files
Steve Tedder
Central Files
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
•
MEMORANDUM
•
AIR QUALITY SECTION
TOXICS PROTECTION UNIT
April 14, 1993
TO: Arthur'Mouberry, Chief, Groundwater Section ,H/
THROUGH: Alan Klimek, Chief, Air Quality Section(Y
THROUGH: Lee Daniel, Assistant Chief Technical Services~
. l'if,l'\h . ' t . t t~r /.t FROM: Beth Mileson;-p .D., Toxicologis , Toxics Pro ec ion Uni
SUBJECT: FCX-Washington NPL Site (Superfund Site)
I have reviewed the Air Investigation portion of the Draft Remedial Investigation/Feasibility study Report for the FCX Washington Site, document number 7740-008-DR-BHHD, prepared for the us EPA. The air samples collected on the site contained a number of pesticides at concentrations at least twice the concentrations found in background samples. Pesticides found in particularly high concentrations were Heptachlor, DDT, Lindane, and alpha and gamma Chlordane. Currently, the Air Quality section has no regulatory authority over these pesticides.
Human exposure to these pesticides may result in cancer or non-cancer illnesses. The effect of most concern for inhalation of these pesticides is cancer. The risk a person has of contracting cancer due to inhalation of these pesticides was calculated and presented in the FCX document. Lifetime risks were calculated for full-time residents exposed for 24 years, workers on site 250 days per year for 25 years, and visitors to the site.
In North Carolina, our Acceptable Ambient Levels (AALs) are based on an "acceptable" public risk of one person contracting cancer for every 1,000,000 people exposed to a given concentration for a life time. This is a 1 x 10-• risk. Some of the inhalation risks presented in this document are greater than the 1 x 10-• risk used to establish AALs in North Carolina.
The inhalation risk to an adult resident of source Area 3 (the only area considered residential) is 7.2 x 10-•, or 7.2 cancer cases per 100,000 people exposed. There are additional risks due to residing in Area 3, due to dermal exposure, incidental ingestion of soil, and ingestion of local fish, all contaminated by the same pesticides. The total risk for an adult resident is 3. 4 cases expected per 10, oo·o people exposed for 25 years ( 3. 4 x 10-• risk) . This is a high risk. The risk of child visitors to any site contracting cancer due to inhalation of the pesticides -is very
• •
small ( 2 x 10-10 to 5 x 10-12 ), because the duration of exposure is
short. The calculated inhalation risks for workers are slightly
higher than recommended for the general public, but the highest
concentrations of pesticides detected are well below the Threshold
Limit Values recommended by the ACGIH for workers.
Pesticide contamination of the air occurs inside buildings on
the FCX Washington site. Residents of Area 3 have the highest risk
of contracting cancer due to pesticide exposure, and this risk is
greater than the risk deemed acceptable. Workers on the site are
at a slightly increased risk for contracting cancer due to
inhalation of pesticides, but the risk is not excessive. A visitor
to the site is exposed to a minuscule risk of contracting cancer
due to inhalation of pesticides. We recommend that the agency that
overseas this project do what is necessary to reduce the risks to
the resident population.
cc: Lori Cherry, supervisor, Toxics Protection Unit
Dr. John Freeman, Director, Environmental Epidemiology Section
Victor Copelan, Air Quality Regional Supervisor
Jim Mulligan, Regional DEM supervisor
::,
MEMORANDUM
! I
SUBJECT: In-house Remedial Investigation and Feasibility
Study ( RI /FS) at the FCX, Inc. 1-Sta.tesville Site
Statesville, North Carolina
FROM: McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
TO: Bill Bokey, ESD
Winston Smith, ATPD
Bernie Hayes, GWTU
Elmer Akin, Risk Assessment
Suzanne Durham, CRC
Marcia Owens, ORC
Chuck Pietrosewicz, ATSDR
Grover Nicholson, NCDEHNR
Hagen Thompson, OPA
PURPOSE: The purpose of this memorandum is to inform you
that an In-house RI/FS has been initiated by EPA-Region IV
for the FCX, Inc. -Statesville site in Statesville, North·
Carolina. I request the help of you and your staff in
planning the work, performing the Remedial Investigation and
Feasibility Study, and preparing the actual reports. The
ARCS contractor Roy S. Weston has been tasked to provide
support for some of the work.
BACKGROUND: The Farmers Cooperative Exchange, Inc. (FCX)
repackaged and distributed various pesticides at the site
from about 1940 until the late 1960s. According to a former
plant manager, approximately 5,000-10,000 pounds of
pesticides were buried in a trench under what is now the FCX,
Inc. warehouse. These pesticides reportedly included DDT,
TOE, Lindane, and Chlordane.
On May 6 and 7, 1986, a site inspection was performed by the
North Carolina Department of Environmental Health and Natural
Resources (NCDEHNR). Analyses of soil and groundwater
samples indicated contamination with DDT, Lindane, and
Chlordane.
-· •
-2-
OBJECTIVE: A tentative timeline has been developed for the
start of the RI/FS process with the following dates:
TASK
Initial Scoping meeting
Draft Work Plans
Fieldwork
RI Report
DATE
November-December 1990
January 1991
March 1991
July-August 1991
I will be contacting you soon regarding: 1) the initial
scoping meeting and 2) any support your staff may be able to
provide. Please contact me at [phone] if you have any
questions regarding this matter.