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Home My WebLink AboutNCD095458527_20060928_FCX Inc. (Statesville)_FRBCERCLA FYR_Five-Year Review-OCR,. ' e: ..... _. .. ,_ · .. ~ ~~:: ·. -·. ·" ..... , ..... • .• .~·~ --,1:----- r-,;( ;~ .. i/ ·,( ,7" ;·~ ' ' 'r .. ', I ' ' j 11, '' ; , ,i OCT O 5 2006 •·;,} , l ,,_ JI ' I I / ,' ';,~." .. 1: -_,--;~~-· ,., Superfund Five-Year Revi'ew-Report·~~ .'. ''..~_!,J FCX-Statesville Superfund Site, Statesville, Iredell County, North Carolina EPA ID: NCD 095458527 Prepared for US EPA Region 4 September 2006 Prepared by the North Carolina Department qf Environment & Natural Resources : Beverly H. Banister, Acting Division Director Waste Management Division US EPA Region 4 q-zg-o~ Date Five-Year Review FCX-Statesville • • Page i Statesville, Iredell County, NC Table of Contents Table of Contents .................................................................................................................. i List of Acronyms ....................................... : ................................................................................................. .iv Executive Summary ..................................................................................................................................... 1 Five-Year Review Summary Form ............................................................................................................... 3 1.0 Introduction .................................................................................................................................. 4 2.0 Site Chronology............................................................................................................................ 5 3.0 Background ................................................................................................................................... 6 3.1 Site Description ............................................................................................................... 6 3.2 Site Topography, Geology, and Hydrogeology ...... : .................................... : .......... 7 . 3.3 Land and Resource Use .................................................................................................... 9 3.4 History of Contamination ................................................................................................... 9 4.0 Brief Summary of OU1, OU2, and OU3 Remedial Actions ........................................................ 13 4.1 Remedy lmplementation ................................................................................... 15 4.2 System Operation/Operation &Maintenance ................................................................... 19 5.0 Progress Since Last Five-Year Review ...................................................................................... 21 6.0 Five-Year Review Process ........................................................................................................... 21 6.1 Administrative Components .................................................................... : ............ : ........... 21 6.2 Community Involvement.. ................................................................................................. 21 6.3 Document Review ......................................................................................................... : .. .21 6.4 ARAR Review .......................................... : ....................................................................... 22 6.5 Data Review .................................................................................................................... 23 6.6 Site Inspection .................................................................................................................. 36 6.7 Interviews ..................................................................................................... : ................... 37 7.0 Technical Assessment... .......................... : ..................................................................................... 37 7.1 Question A: Is the remedy functioning as intended by the decision documents? ............. 37 7.2 Question B: Are the exposure assumptions, toxicity data, clean-up levels and Remedial Action Objectives (RAOs) used at the time of the remedy still valid? .............. 38 7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? .................................................................................. 39 7 .4 Technical Assessment Summary ..................................................................................... 39 8.0 Issue to Address ........................................................................................................................... 40 9.0 Recommendations & Follow-up Actions ....................................................................................... 41 10.0 Protectiveness Statement... ........................................................................................................ :.42 11.0 Next Review ................................................................................................................................... 42 Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Tables Page ii Table 1 Chronology of Site Events ............................................................................................................ 5 Table 2 Groundwater Remediation Levels in 1993 OU1 ROD: .................................................................. 16 Table 3 Soil Remediation Levels in 1994 OU2 ROD ...................... : ...................................................... 16 Table 4 Groundwater Remediation Levels in 1996 OU3 ROD .......................................................... 17 Table 5 Groundwater Remediation Levels for Amended OU1 Remedy ............................................ 17 Table 6 List of the OU3 MNA Wells Sampled in Fall 2005 ............................ : ...................................... 32 Table 7 List of the Source Area Wells Sampled in Fall 2005 ............................... , ................................. 34 Table 8 Recommendations and Follow-Up Actions ......................................................................... , ..... .41 )Figures Figure 1 Site Location Map ...................... : .......................................................................................... 8 Figure 2 Site-wide Groundwater Monitoring Well Locations ........................................................... 24 Figure 3 OU2 Excavation Areas .............................................................................................. 29 Figure 4 OU3 Source Area Wells and Monitoring Probe Locations .................. ." .............................. 31 Figure 5 OU3 MNA Well Location Map .......................................................................................... 33 Figure 6 PCE Shallow lso-concentration Map for OU3 Source Area .................................................. 35 Attachments Attachment 1: List of Documents Reviewed Attachment 2: Site Inspection Checklist Attachment 3: Community Notice Attachment 4: Complete Interviews Five-Year Review FCX-Statesville • • Page iii Statesville, Iredell Coynty, NC AES ANA AOC ARAR AS/SVE BCD BNA BRA CERCLA cis-DCE CFR COG 1,1-DCA EISOPQAM ESD FCX FS GAG HRS IC MCL MNA MW NCAC NC DENR NCDHR NCP List of Acronyms Applied Earth Science Accelerated Natural Attenuation Administrative Order on Consent Applicable or Relevant and Appropriate Requirement. Air Sparging/Soil Vapor Extraction Base Catalyzed Decomposition Below Land Surface Base Neutral Acids Baseline Risk Assessment Comprehensive Environmental Response, Compensation, and Liability Act cis-1,2-dichloroethene Code of Federal Regulations Contaminant of Concern cis-1, 1-dichloroethane Environmental Investigation Standard Operating Procedure and Quality Assurance Manual Explanation of Significant Difference Farmers Cooperative Exchange Feasibility Study Granulated Activated Carbon Hazard Ranking System Institutional Controls Maximum Contaminant Level Monitored Natural Attenuation Monitoring Well North Carolina Administrative Code North Carolina Department of Environment and Natural Resources North Carolina Department of Human Resources National Contingency Plan Five-Year Review FCX-Statesvil/e • Statesville, Iredell County, NC NCSWQS NPL O&M OSHA OU PAH PCE PCOR PCP POTW ppb QA/QC RA RAO RD RI ROD RPM TCE TEO US EPA voe North Carolina Surface Water Quality Standards National Priority List Operation and Maintenance Occupational Safety and Health Administration Operable Unit Polynuclear Aromatic Hydrocarbons Tetrachloroethene Preliminary Close-Out Report Pentachlorophenol Publicly Owned Treatment Works Parts per billion, also designated as ug/1 Quality Assurance/Quality Control Remedial Action Remedial Action Objective Remedial Design Remedial Investigation Record of Decision Remedial Project Manager Total Organic Carbon Toxicity Equivalent Quotient United States Environmental Protection Agency Volatile Organic Compound • Page iv Five-Year Review FCX-Statesvil/e • Statesville, Iredell County, NC • Page I Executive Summary The FCX Superfund site (the "Site") consists of the former FCX property and the former Burlington Industries textile plant property. The Site is located in a mixed residential and commercial area at the intersection of Phoenix Street and West Front Street (Highway 90), approximately 1.5 miles west of downtown Stat~sville, Iredell County, North Carolina. From 1986 to 1990, a number of environmental studies were performed at the former FCX property. These studies indicated the presence of pesticide contamination in the soil, and both pesticide and volatile organic compound contamination in the groundwater. The Hazardous Ranking System (HRS) was used to score the Site and qualify the Site for proposal and placement on the National Priorities List (NPL). EPA proposed the Site for NPL listing in June 1988 and was finalized on the NPL on February 21, 1990. From 1991-1993, EPA conducted an extensive RI/FS at the former.FCX property and south thereof. Based on the RI data, and the observed groundwater flow direction and pattern of groundwater contamination, it was concluded that the source of the VOC contamination originated on the former Burlington property located immediately to the north of the former FCX property. Based on this information, the US EPA signed an Administrative Order on Consent (AOC) with Burlington Industries and El Paso Natural Gas Company (EPNG). Under the terms of this AOC, a separate RI/FS was conducted to characterize VOC contamination associated with the former Burlington property. The US EPA expanded the Site to include the VOC contamination associated with the former Burlington property. After expanding the Site, the US EPA divided the Site into three operable units (OUs), each OU with a separate remedy, to address the contamination at the. Site. The OU1 and OU2 Records of Decision (RODs) were signed in September 1993 and November 1994, respectively, to address soil and groundwater contamination on the former FCX property and south thereof. The OU3 ROD was signed in September 1996 to address the VOC contamination on and around the former Burlington property. Since 1998, the OU1 remedy has addressed contaminated groundwater at the former FCX property and south thereof. Completed in 2001, the OU2 remedy addressed the pesticide soil c'ontamination on the former FCX property. The OU3 remedy uses air sparging (AS), soil vapor extraction (SVE), and Monitored Natural Attenuation (MNA) technology to address soil and groundwater contaminated with VOCs on and around the former Burlington property. In 2006, changes have been made to the OU1 and OU2 remedies. A ROD Amendment was issued in September 2006, changing the OU1 groundwater remedy from pump-and-treat technology to Monitored Natural Attenuation .(MNA). The ROD Amendment not only changes the OU1 remedy, but also removes metals, VOCs, and one semi-volatile organic compound as Contaminants of Concern (COCs) from the OU1 remedy. An Explanation of Significant Difference (ESD) was also issued in September 2006 to enhance the OU3 remedy with the use of Accelerated Natural Attenuation. With the OU 1 and OU3 remedy changes described above, the OU3 remedy will be the sole means by which VOC groundwater contamination will be ' addressed at the Site. · Five-Year Review .FCX-Statesville • Statesville, Iredell County, NC • Page 2 This is the first Five-Year Review for the FCX-Statesville Site and is a policy review. A policy review is conducted when "a remedial action that, upon completion, will not leave hazardous substances, pollutants, or· contaminants on-Site above levels that allow for unlimited use and unrestricted exposure, but requires five years or more to complete" (US EPA Comprehensive Five-Year Review Guidance, June 2001). The following issue has been identified during this Five-Year Review: The 1993 ROD specified the use of deed restrictions on the former FCX property to prohibit the use of groundwater. However, since the 1980's when FCX was permitted by the Bankruptcy Court to abandon their property, deed restrictions have not been placed on the former FCX property. This is the issue which needs to be addressed in the future w_hen the former FCX property is sold. EPA has determined that in lieu of using deed restrictions, an institutional control {IC) such as a deed notice, restrictive covenant, etc., should be used. EPA has informed perspective purchasers of the former FCX property that an institutional control will need to be implemented. [?ecommendations and Follow-up Actions: Major recommendations: Implement the amended OU1 remedy and enhanced OU3 remedy, including the use of Institutional Controls in each remedy, to ensure the use of grou·ndwater is prohibited in the area affected by Site-related groundwater contamination, until the EPA and/or the NC DENR makes the determination that the Site-related groundwater remediation levels have been met, and the groundwater is safe for use. Protectiveness Statement: The OU1, OU2 and OU3 remedies remain protective of human health and the environment in the short-term for the following reasons: • there are no human or ecological exposure pathways to Site-related1 contamination; • the levels of pesticides in groundwater on the former FCX property and south thereof have been reduced to levels approaching the remediation levels in the OU 1 ROD; • the levels of total pesticides in soil on the former FCX property have been reduced to the remediation levels; · • the levels of VO Cs in soil and groundwater on and around the former Burlington property have been significantly reduced during the OU3 Remedial Action; · • the amended MNA remedy will continue to be protective of human health and the environmerit on the former FCX property and south thereof, and the enhanced OU3 remedy will continue to be protective of human health and the environment on and around the former Burlington property; and • institutional controls, including restrictive covenants, need to be implem.ented on the former FCX property to ensure the long-term protection of human health and the environment at the Site. In addition, the City of Statesville will be contacted twice a year (consistent with the OU3 remedy) to ensure no one is viola.ting the City Ordinance (Municipal Code 23-276) within the area affected by Site-related groundwater Five-Year Review FCX-Statesville • Statesville, Iredell County, NC contamination. • Page 3 . . ' Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Five-Year Review Summa Site name (from WasteLAN): FCX Statesville Superfund Site EPA ID (from WasteLAN): NCD095458527 Region: 4 City/County: Statesville, Iredell County NPL status: IBJ Final D Deleted D Other (specify) Remediation status (choose all that apply): D Under Construction IBJ Operating llil Complete Page 4 Multiple OU.s?· IBJ YES ONO Construction completion date: 9/28/2001 Has site been put int.a reuse? D YES IBJ NO ! REVIEW STATUS Lead agency: IBJ EPA O State O Tribe O Other Author(s) name: Nile Testerman/ Stephanie Grubbs Author(s) title: Author(s) affiliation: NC DENR . Engineer/Hydrogeologist Review period: 1 / 1 / 2006 to 9/28/2006 Date(s) of site inspection: 4/11/2006 Type of review: Policy Review number: IB] 1 (first) D 2 (second) D 3 (third) D Other ·Triggering Action: D Actual RA Onsite Construction at OU # __ □Actual RA Start IB:lconstruction Completion D Previous Five-Year Review Report □Other Triggering action date (from WasteLANJ: 9126 I 2001 Due date (five years after triggering action date): 9 / 28 / 2006 Five-Year Review FCX-Statesville • Statesville, Iredell County, NC 1.0 Introduction • Page 5 The purpose of conducting a Five-Year Review is to determine whether the remedy (or remedies) at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and identify recommendations to address them. The North Carolina Department of Environment and Natural Resources (NC DENR) is preparing this Five-Year Review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the. National Contingency Plan (NCP). CERCLA §121 states: If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgement of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews. The United States Environmental Protection Agency (US EPA) interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4 )(ii) states: If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than eve,y five years after the initiation of the selected remedial action. The NC DENR, Division of Waste Management, Superfund Section, conducted this Five-Year Review of the three (3) remedies implemented at the FCX-Statesville Superfund Site located in Statesville, Iredell County, North Carolina .. The Site consists of three operable units: the OU1 remedy involving groundwater pump-and-treat since 1998; the OU2 remedy (completed in 2001) which involved soil excavation and on-Site treatment with thermal desorption; and the OU3 remedy involving MNA since 1998 and AS/SVE since 2001. The OU1 remedy change from pump-and-treat to MNA, as well as the OU3 remedy enhancement which adds ANA to the existing remedy, were evaluated as part of the Five-Year Review. This review was conducted from January 2006 through September 2006. The Site inspection for the Five-Year review was conducted by EPA and NC DENR personnel on April 11, 2006. This report documents the results of this review. Five-Year Review FCX-Statesville • · Statesville, Iredell County, NC • Page 6 This is the first Five-Year Review for the Site. The triggering action for this policy review is five years from the date all three remedies were built and determined to be operational and functional, which was September 28, 2001. A policy review is conducted when a "remedial action that, upon completion, will not leave hazardous substances, pollutants, or contaminants on site above levels that allow for unlimited use and unrestricted exposure, but requires five years or more to complete" (US EPA Comprehensive Five-Year Review Guidance, June 2001 ). This Five-Year Review was performed in a manner consistent with the latest US EPA Comprehensive Five-Year Review Guidance (US EPA, 2001 ). 2.0. Site Chronology Table 1 lists the site chronology for selected events for the Site. Table 1 -Chronology of Site Events I Event I Date Farmers Cooperative Exchange (FCX) began operations. Including 1940 formulation, repackaging, ·warehousing, and distribution of farm chemicals (pesticides and fertilizers) and milling and sale of feed grains. Repackaging of liquid pesticides was discontinued, and dust repackaging 1966, 1969 discontinued. Discovery of the Site by NC DENR. 1986 Preliminary Assessment completed by NC DENR. · , April 4, 1986 FCX filed a voluntary petition under the provisions of Chapter 11 of the US September 17, 1986 Bankruptcy Code. Site Inspection completed by NC DENR. June 3, 1987 Hazard Ranking_ System (HRS) package completed. October 1 , 1987 Site proposed for listing on the National Priorities List (NPL). June 24, 1988 EPA conducted an emergency removal action at the Site. January 1989 - January 1990 Final listing on NPL. February 21,.1990 EPA conducted an in-house Phase I Remedial Investigation, which involved . Fall 1991 extensive s_ampling on-and off-site soif, groun_dwater, surface water, and sediment. EPA conducted Phase II of the RI, which was an expanded investigation of June 1992 groundwater quality and alleged pesticide burial pits. Administrative Order on Consent signed for OU3 RI/FS. June 25, 1993 Baseline Risk Assessment (BRA) for the FCX property was completed. _July 1993 Record of Decision (ROD) signed to address OU1. The major component of September 27, 1993 this ROD was to address groundwater contamination on a portion of the site. ' Risk and Health Assessment completed for OU2 RI/FS. June 23, 1994 I Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Ecological Risk Assessment completed for OU2 RI/FS. • Combined Remedial Investigation (RI) and Feasibility Study (FS) complete for OU1 and OU2. ROD signed to address OU2. The major component of this ROD was to address pesticide soil contamination at the Site. Remedial Design (RD) completed for OU1 and OU2. Combined Remedial Investigation (RI) and Feasibility Study (FS) complete for OU3. ROD signed to address OU3. Underground Storage Tanks removal at the FCX property. RD completed by Potentially Responsible party (PRP) for OU3. Groundwater Optimization Report completed for OU1 remedy. Preliminary Close-Out Report (PCOR) completed for the Site. Construction Completion Report for the Phase II Air Sparging and Soil Vapor Extraction System report submitted to the US EPA. Pre-Design Investigation for Accelerated Natural Attenuation report submitted. ROD Amendment signed for OU 1 . ESD signed for OU3. 3.0 Background 3.1 Site Description Page 7 June 23, 1994 November 22, 1994 November 22, 1994 June 21, 1996 September 30, 1996 September 30, 1996 May 1999 June 9, 2000 March 9, 2001 September 28, 2001 December 2003 January 2006 September 8, 2006 September 11, 2006 The Site consists of the former FCX property and the former Burlington property. The Site is located in a mixed residential and commercial area at the intersection of Phoenix Street and West Front Street (Highway 90), approximately 1.5 miles west of downtown Statesville, North Carolina. Statesville is located in Iredell County approximately 60 miles north of Charlotte. The former FCX property is approximately 5.5 acres in size. The coordinates of the former FCX property are latitude 35° 4 7'11" north, longitude 80° 54'58" west. The former FCX property is bounded to the north by the Norfolk-Southern Railroad and former Burlington Industries plant property, the former Carnation Milk Company property to the west, residential and small business properties along the south side of West Front Street, and a prefabricated utility and sales lot on the east side of Phoenix Street. Prior to the late 1960's, the main structures on the former FCX property 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. During the late 1960's, most of these buildings (with the exception of the smal_l office building) were Five-Year Review FCX-Statesvil/e • Statesville, Iredell County, NC • Page 8 demolished. A large brick warehouse was constructed on-site around 1969-1970, 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 former FCX property to the east of the two warehouses is covered with gravel, and contains a large reinforced slab and smaller concrete tractor trailer pads. The former FCX property is fenced except for the paved parking lot and loading dock area along West Front Street. Ten (10) OU1 groundwater extraction wells are located on the former FCX property running in a line from the southwest to northeast corners of the site on approximately 50 feet centers .. The OU1 groundwater treatment system is housed in a prefabricated metal structure in the southeast corner of the FCX property. The former Burlington property is approximately 10 acres in size. The majority of the former Burlington property is covered by two large buildings, a warehouse and the main building. The former Burlington property is bounded on the north by a residential neighborhood, to the south by the Norfolk-Southern Railroad and the fo·rmer FCX property, to the west by an unspecified industrial plant, and to the east by Phoenix Street. The former Burlington property is completely .fenced except for the front parking· area between the former plant and Phoenix Street. Figure 1 shows the Site location map. 3.2 Site Topography, Geology, and Hydrogeology The Site gently slopes to the south at the former FCX property, and slopes to the north at the northern end of the former Burlington property. The Site lies within the Blue F~idge-lnner Piedmont Geologic Belt. This Belt generally consists of metamorphic rocks including gneiss and schist, as well as gradations of these two types. Most of these rocks near the surface have weathered into a layer of "overburden" overlying the fractured but relatively unweathered bedrock. The overburden ranges in thickness from 15 to 65 feet at the Site, and consists of saprolite and residual soils interspersed with unweathered gneiss/schist, and to a lesser decree, alluvium. Granitic intrusions are also common in the area. Soils in the general area belong to the Lloyd Association. These soils are characterized as deep, well-drained soils with a subsoil of dark red clay. Groundwater at the Site occurs in an unconfined to semi-confined aquifer consisting of 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 generally ranges from 27 to 35 feet below land surface (bis). During wetter periods of the year, groundwater may intersect the ground surface around the Site and become overland or surface water flow. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC N ,\/ ·, /_:.:.._. ----.= ~ .. .---•-Q.;_-___ -:::; :. .• :; ---:~-. -'=. 1= =:.= -! --. ~~ -<-· · · e~e;' FIGURE 1 • Page 9 SITE LOCATION MAP Five-Year Review FCX-Statesville · • Statesville, Iredell County, NC • Page 10 The January 1999 OU1 Remedial Action (RA) Report indicates the FCX property is located in a hilltop topographic setting. Such a hilltop location is generally characterized as a groundwater recharge zone. In groundwater' recharge zones, groundwater flow usually has a downward component, and the migration of contaminants into deeper parts of the aquifer may be enhanced in such areas. Water quality data suggests that this is the case at the former FCX property. The soil permeability, or hydraulic conductivity, controls the a·mount of groundwater recharge, surface water run-off and percolation, and the rate of contaminant migration through the saturated zone. At the Site, the permeability is relatively low within the saprolite layer. However, the bedrock hydraulic conductivity is typically highly variable, with limited zones of high or moderate permeability along rock fractures, separated by substantial interfracture areas of extreme low or no permeability. The contrast in hydraulic conductivity between the bedrock and saprol_ite may facilitate groundwater flow downward from the saprolite to the bedrock. The · hydraulic gradient appears to steepen toward the south and east and the Site's variable gradient may suggest that the Site lies within a groundwater divide. 3.3 Land and Resource Use The Site is located in a mixed residential/commercial/industrial area at the intersection of Phoenix Street and West Front Street, approximately 1.5 miles west of downtown Statesville, North Carolina. The City of Statesville's Municipal Code Section 23-276 requires all residents to use City-supplied water within the City limits. The use of private water wells within.the City limits is only permitted upon request and with . . permission from the Iredell County Health Department. As part of the OU3 remedy, . EPNG placed a restrictive covenant on the former Burlington property prohibiting the use of groundwater. In addition, EPNG contacts the City of Statesville on a yearly basis to make sure no residents in the affected area have been granted permission to install and use a private well. 3.4 History of Contamination FCX began operating at the Site as an agricultural supply distribution center about 1940 and continued to operate until declaring bankruptcy in 1986. The former FCX property 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 was later discontinued in 1969. Testimony from previous employees indicates that 5,000 to 10,000 pounds of DDT, DDE, and possibly liquid chlordane were disposed on-Site in two trenches, buried under six-feet of soil, and later covered with reinforced, eight-inch thick concrete slab and warehouse. · Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 11 Previous investigations conducted prior to the Remedial Investigation on the former FCX property were conducted by Southern States Cooperative (Fred C. Hart), the NC Department of Human Resources (NCDHR, currently NC DENR), and the US EPA Region IV Emergency Response. The Fred C. Hart investigation in February 1986 resulted from a pre-purchase environmental evaluation on behalf of Southern States Cooperative. Several soil samples were collected and permanent monitoring wells installed on the former FCX property. Data collected indicated pesticide contamination in the soils and pesticide and volatile organic compounds (VOCs) in the groundwater. In May 1986, NCDHR conducted a Site Inspection collecting soil and groundwater samples on and around the former FCX property, including a water supply well west of the former FCX property. Pesticides were detected in soil and groundwater on and around the former FCX property, and lindane, fluorocarbons,.VOCs, and caprolactum were identified in groundwater samples. In September 1986, FCX filed a voluntary petition under the provisions of Chapter 11 of the US Bankruptcy Code. The US EPA, NCDENR, and FCX entered into a settlement agreement, whereby FCX established a trust to settle its liability at the former FCX property. A Bankruptcy Court permitted FCX to abandon the property, and as of September 2006, no one has purchased the former FCX property. In January 1989, the US EPA Region IV Emergency Response conducted an emergency sampling investigation at the Site. Extensive exploratory borings were drilled through the main warehouse in an attempt to locate the alleged trenches. However, the efforts to locate the trenches were unsuccessful. Monitoring wells were installed on site (two within the saprolite portion of the aquifer and two within the bedrock portion). Pesticides were detected in all groundwater samples. The Site was evaluated using the Hazard Ranking System (HRS) and was proposed for inclusion on the NPL on June 24, 1988. The Site was finalized on the NPL on February 21, 1990. The US EPA initiated the RI/FS on and around the former FCX property in September 1990. The Remedial Investigation/Feasibility Study (RI/FS) at the former FCX property was conducted from 1991 to 1993. The objectives of the RI conducted on the former FCX property were to characterize the soil and groundwater contamination on the former FCX property. Another objective of the RI was to locate the alleged pesticide burial pit if possible. Extensive surface and subsurface soil sampling was conducted on the former FCX property. Soil samples were collected across the former FCX property, including beneath the two existing warehouses. The area beneath the warehouses was of particular interest because these were the areas where the pesticide formulation and blending had taken place years before, and where the alleged burial pit was located. Five-Year Review FCX-Statesville Statesville, Iredell County, NC • • Page 12 A total of thirteen pesticides were identified in both surface and subsurface soil, including DDT, DDD, DDE, pentachlorophenol, alpha-chlordane, gamma-chlordane, dieldrin, endrin, heptachlor, heptachlor epoxide, alpha-BHC, gamma.-BHC (lindane), and aldrin. The most.widely identified pesticides in ttie soil were DDT and its transformation products DDD and DDE. The highest concentration of DDT in the soil was identified beneath one of the warehouses at a concentration of 830,000 ug/kg (parts per billion, or ppb). A total of twenty-one (21) extractable organic compounds were identified in the surface and subsurface soil during the RI. Nineteen (19) of the 21 compounds were poly-cyclic aromatic hydrocarbons (PAHs), including pyrene, fluoranthene, anthracene, perylene, phenanthrene, benzo(b/k) fluoranthene, chrysene, benzo(a)anthracene, benzo(a)pyrene, indeno(1,2,3-CD)pyrene, and dibenzo (A,H) anthracene. The elevated levels of these poly-cyclic aromatic hydrocarbons (PAHs) in the soil are more than likely associated with crcissties underlying the railroads tracks located adjacent to the on-Site warehouses. In addition to the extractable organic compounds, forty (40) additional extractable organic compounds (listed mostly as unidentified compounds) were detected in the soil during the RI. The Phase I soil sample results indicated presumptive evidence of dioxins and furans. As a result, an additional forty-three (43) soil samples were collected and analyzed from twenty-one (21) locations. Dioxin was present in the soil beneath the larger warehouse at concentrations below the Toxicity Equivalent Quotient (TEO) concentration of one part-per-billion (ppb). Soil samples were also collected and analyzed to provide total organic carbon (TOC) values for evaluating the fate and transport of the Site-related contaminants in the soil. Two samples were collected from depths of 25 feet and 35 feet below land surface. Both samples contained the pesticides DDT, DDD, pDE, and gamma-chlordane at concentrations up to 20 ppb, as well as several BHC isomers, endrin, and heptachlor at concentrations below 20 ppb. Groundwater sampling was conducted in two separate phases during the RI on the FCX property, the first in June 1991, and the second in June 1992. A total of twelve (12) on-Site monitoring wells were sampled. Groundwater samples were also collected from the off-Site supply well (on the former Carnation property) located approximately 800 feet to the west of the former FCX property, as well as three (3) private drinking water wells located south of the Site in a downgradient direction. A to_tal of nine (9) pesticides were identified in the on-Site monitoring wells, including alpha-BHC, beta- BHC, delta-BHC, gamma-BHC (lindane), dieldrin, endrin Ketone, chlordane, and endrin. The pesticides with relatively high water solubilities, including the BHC compounds and endrin ~etone, were the only pesticides identified in groundwater at concentrations greater than 1 ppb. On ·the other hand, the pesticides with relatively low solubilities such as DDT and its transformation products, were not detected at Five-Year Review FCX-Statesville • Statesville'. Iredell County, NC • Page 13 appreciable concentrations during the RI. The Carnation well revealed the presence of VOCs at elevated concentrations. No pesticide or voe groundwater contamination was identified in samples collected from three private drinking water wells during the RI. A total of seven (7) purgeable or volatile organic compounds (VOCs) were identified in the on-Site groundwater monitoring wells, including tetrachloroethene, trichloroethene, 1, 1, 1-trichloroethane, 1, 1-dichloroethane, chloroform, 1, 1- dichloroethene, and cis-1,2-dichloroethene. Tetrachloroettiene and its degradation products cis-1,2-dichloroethene, trichloroethene, 1, 1, 1-trichloroethane, _ 1,1-- dichloroethene, and 1, 1-dichloroethane were the most commonly identified VOCs in the on-Site wells. The maximum tetrachloroethene concentration was 270 ppb. A qualitative baseline risk assessment (BRA) for the FCX property was completed in July 1993. The BRA defined and summarized unacceptable potential risks posed by the contamination described in the RI for the former FCX property. In summary, under past land use conditions, no unacceptable carcinogenic or non-carcinogenic risks to human health were identified. However, several future land use scenarios were identified which pose unacceptable carcinogenic and non-carcinogenic potential risk. These potential risks included the ingestion or inhalation of contaminated groundwater at the Site by a future child or adult resident, and the dermal contact or ingestion of contaminated surface soil by a future child or adult resident. Potential risks to environmental receptors at or near the Site were evaluated based on surface water and sediment sampling data collected from on-Site or surface water pathways located near the Site. A review of the toxicity of the chemicals of potential concern to potential ecological receptors was also conducted. Use of the Site by terrestrial receptqrs such as birds and small mammals, particularly the area presently covered by the two warehouses and parking lot, was considered unlikely given the lack of trees or other vegetative cover at the Site. Based on a qualitative analysis, terrestrial wildlife communities in the low-lying and wooded areas near the former FCX property are not likely to be significantly impacted. During the extensive sampling for the RI and based on the observed groundwater flow direction and pattern of groundwater contamination, it was concluded that the source of the VOC contamination originated on the former Burlington property located immediately to the north of the former FCX property. Based on this information, the US EPA signed an Administrative Order on Consent (AOC) with Burlington Industries and EPNG on June 25, 1993. Under the terms of this AOC, a separate RI/FS was conducted to characterize voe contamination associated with the former Burlington property. In 1994, the US EPA expanded the Site to include the voe contamination ' . ' Five-Year Review FCX-Statesvif/e • Statesville, Iredell County, NC • Page 14 associated with the former Burlington property since the HRS scoring package included the voe groundwater contamination, and the pesticide and voe groundwater contamination have consistently been detected within the same monitoring wells on the former FCX property and south thereof. Any attempt to address the pesticide contamination in groundwater would also require addressing the voe contamination. By expanding the Site to include the former Burlington property, EPA could address the VOC contamination associated with the former Burlington property. After expanding the Site to include the former Burlington property, the US EPA divided the Site into three OUs or three phases. One comprehensive RI/FS was conducted on the former FCX property and south thereof from 1991 through 1993. The RODs for OU1 and OU2 were signed in September 1993 and November 1994, respectively. · A separate PRP-Lead RI/FS was conducted for OU3 to investigate the voe contamination associated with the former Burlington property. The investigation of soil and groundwater began in February 1994 and involved three phases. Phase I included a soil and gas survey and soil, groundwater, sediment and surface water sampling. Phase II included soil sampling to define the extent of contamination, monitoring well installation and sampling, and collection of geologic/hydrologic data. Phase Ill included additional monitoring well installation and sampling, direct push soil and groundwater sampling; surface water sampling, and additional collection of geologic/hydrologic data. The results of the study revealed elevated levels of metals and VOCs in the soil and groundwater on and around the former Burlington property. The ROD for OU3 was signed in September 1996 to address the contamination associated with the former Burlington property. 4.0 Brief Summary of OU1, OU2, and OU3 Remedial Actions The remedy stated in the OU1 ROD dated September 27, 1993, provides for remediation of contaminated groundwater on the former FCX property and south thereof. Table 2 shows the specified groundwater performance standards as stated in the 1993 ROD. The major components of the selected remedy, as stated in the ROD, include: • extraction of groundwater at the FCX property and to the south of the property that is contaminated above Federal Maximum Contaminant Levels (MCLs) or the North Carolina 2L Groundwater Standards, whichever is more protective; • on-Site treatment of extracted groundwater via chemical precipitation/filtration and carbon adsorption; • discharge of treated groundwater to the local Publicly Owned Treatment Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Works (POTW); • Page 15 • monitoring of groundwater entering and exiting the treatment system, as well as monitoring of the groundwater quality across the site for an estimated 30 years; and • the use of deed restrictions in the affected area to prohibit the consumption of contaminated groundwater. The original OU1 ROD was modified by a ROD Amendment on September 11, 2006. The ROD amendment modifies the groundwater remedy documented in the 1993 ROD from pump-and-treat technology to Monitored Natural Attenuation (MNA). The ROD Amendment not only changes the remedy selected in the original ROD, but also removes metals, VOCs, and the compound bis(2-ethylhexyl)phthalate as Contaminants of Concern (COCs) from the OU1 remedy. Table 5 shows the amended groundwater remediation levels for OU1 as stated in the.ROD Amendme.nt. The ROD Amendment made the following fundamental changes to the OU1 groundwater remedy: • eliminates the extraction of groundwater via the 10 on-site extraction wells; • eliminates the treatment of groundwater with carbon adsorption and precipitation/filtration; • eliminates the discharge of treated groundwater to the City of Statesville POTW; and • removes metals, VOCs, and the compound bis(2-ethylhexylthalate) from the list of COCs, and modifies a few of the remediation levels for pesticides. The OU2 .ROD was signed on November 22, 1994. The OU2 remedy addressed the soil contamination on the former FCX property. Table 3 shows the specified soil remediation levels as stated in the OU2 ROD. The major components of the OU2 remedy, as stated in the ROD, included: • excavating an estimated 15,164 tons of contaminated soil and stockpiling the soil on-Site in preparation for treatment; • treating the contaminated soil and liquid residual on-Site using thermal desorption and base catalyzed decomposition; Five-Year Review FCX-Statesvilfe • Statesville, Iredell County, NC • • backfilling the excavated areas with the treated soil; • decontaminating the warehouses; and • re-constructing the concrete floors in the warehouses. Page 16 The OU3 ROD was signed on September 30, 1996. The OU3 remedy provides for the remediation of soil and groundwater contaminated with voes using a combination of SVE, AS, and MNA on and around the former Burlington property. Table 4 shows the specified groundwater remediation levels as stated in the 1996 ROD. The groundwater remedy in the OU3 ROD includes the following: treatment of voes using air sparging and soil vapor extraction technologies to reduce the higher concentrations of voes on the former Burlington property; MNA, involving the monitoring of groundwater quality on and around the former Burlington property for evidence that natural attenuation is occurring; and the use of institutional controls, including a restrictive covenant on the former Burlington property, to prohibit the use of contaminated groundwater. An Explanation of Significant Difference (ESD) was signed on September 8, 2006. The ESD enhances the existing OU3 remedy by adding Accelerated Natural Attenuation (ANA). ANA will involve the injection of electron donors and possibly microbes into the aquifer to accelerate the natural attenuation of voes in the aquifer, thereby speeding up the remediation of the voe contamination in groundwater on and around the former Burlington property. · 4.1 Remedy Implementation A separate Remedial Design (RD) Report was developed for each of the three operable units. The OU1 RD provided the technical detail needed to,complete the . construction of, and operate and maintain, the OU1 groundwater pump-and-treat system. The OU2 RD provided the technical detail needed to complete the excavation and on-site thermal treatment of an estimated 15,164 tons of pesticide-contaminated soil, as well as treatment of the liquid residual with the base catalyzed decomposition process. The OU3 RD, approved in March 2000, provided the technical detail needed to complete construction of, and operate and maintain, the AS/SVE/MNA remedy on . and around the former Burlington property. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 17 Table 2: Groundwater Remediation Levels in 1993 OU1 ROD CONTAMINANT Federal MCL 15ANCAC 2L (ug/1) (ug/1) Beryllium 4 - Chromium 100 50 Manganese 200 50 Vanadium -- Alpha-Chlordane 2 0.027 Gamma-Chlordane -0.027 . Dieldren -- Heptachlor Epoxide 0.2 0.038 Alpha-BHC -- Beta-BHC -- Gamma-BHC (Lindane) 0.2 0.027 Bromodichloromethane 100 -- Chloroform 100 0.19 Chloromethane --- 1, 1-Dichloroethane --- 1, 1-Dichloroethene 7 7 Tetrachloroethene 5 0.7 Trichloroethene 5 2.8 Bis(2-ethylhexyl) phthalate 6 -- 15A NCAC 2L -North Carolina Adm1n1strat1ve Code specifying State Groundwater Class1ficat1on and Standards. --no Federal MCL or State Standard has been established. --ug/1 = micrograms per liter or ppb Table 3: Soil Remediation Levels in 1994 OU2 ROD CONTAMINANT Soil Remediation Level (Clean-up Goal) mg/kg Total pesticides • 1 Pentachlorophenol 0 3.2 a Defined as gamma-BHC (Lindane), endrin, dieldren, chlordane, DDT, and DDD. b Applies only to the top one foot of soil. Five-YfJar Review FCX-Statesville • Statesville, Iredell County, NC • Page 18 Table 4: Groundwater Remediation Levels in 1996 OU3 ROD CONTAMINANT Remediation Level (ug/1) Aluminum 50-200 1 Arsenic 50" Barium 2000'. Iron 300" Lead 15 ° Manganese 50' Bis(2-ethylhexyl)phthalate 3, Carbon Tetrachloride 0.3 ° Chloroform 0.19, 1, 1-Dichloroethene 7 ,., Cis-1,2-Dichloroethene 70 <.o 1,2-Dichlorpropane 0.5 ° . Methylene Chloride 0.7 4 Tetrachloroethene 5 0 Trichloroethene 2.8 4 · Vinyl Chloride 0.015 2 ' 1 National Secondary Drinking Water Standard, 15A NCAC 2L -North Carolina Administrative Code specifying State Groundwater Classification and Standards, 3 Maximum Contaminant Level (MCL) Table 5: Groundwater Remediation Levels for Amended OU1 Remedy Federal 15ANCAC 2L Contract Remediation CONTAMINANT MCL (ug/I) Quantitation (ug/1) Limit (ug/1) Level (ug/1) Chlordane 2 0.1 0.1 0.1 Dieldren --0.0022 0, 1 0.1 a Heptachlor Epoxide 0.02 0.0038 0.05 0.05 Alpha-BHC ----0.1 0.1 Beta-BHC --0.1 0.1 a Gamma-BHC 0.2 0.2 0.05 0.2 a (Lindane) . . .. .. 15A NCAC 2L -North Carolina Adm1nistrat1ve Code specifying State Groundwater Class1f1callon and Standards. --no Federal MCL or State Standard has been established. ug/I -micrograms per liter or ppb a -in no federal MCL or NCAC 2L exists, the quantitation limit is used. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 19 Following the approval of the OU1 RD in June 1996, the OU1 Remedial Action (RA) was formally initiated as a Long-Term Response Action (L TRA) with the issuance of the RA Statement of Work to EPA's ARCS contractor. OU1 RA activities included construction of the on-Site groundwater treatment system consisting of a 300-gallon influent equalization tank, a 1,200-gallon baffled tank (clarifier), two sand filters with a backwash trickle tank, and two Granulated Activated Carbon (GAC) units. A total of 10 on-site groundwater extraction wells were installed and plumbed into the treatment system. The OU2 RA was initiated with the issuance of the RA Statement of Work to EPA's RAC coritractor. OU2 RA activities included the following: demolition of several on-site structures; transporting demolition debris off-site for disposal; excavation and · stockpiling of an estimated 15, 164 tons of pesticide-contaminated soil inside the warehouses; construction of the thermal desorption system; stack testing of the system as well as ambient air sampling; thermal treatment of the soil followed by testing of the treated soil; backfilling, re-hydration, and compaction of the treated soil into the excavated areas; Base Catalyzed Decomposition (BCD) treatment of the liquid residual resulting from the thermal treatment of the soil followed by testing of the treated residual; decontamination of the warehouses; re-pouring of the concrete floors; and demobilization of the equipment. Following the BCD treatment, the liquid residual was drummed and transported off-site to an EPA-approved disposal facility. The OU3 RA was initiated with the approval of the PRP's RD/RA work plan. The MNA portion of the OU3 remedy began in 1998. The pre-construction meeting for the air sparging/soil vapor extraction system was held on the former Burlington property on May 16, 2000. Construction of the air sparging and soil vapor extraction (AS/SVE) system was completed on August 31, 2000, and a pre-certification inspection was conducted on September 21, 2000. The active source area remediation began on February 1, 2001 with the startup of the Phase I SVE system as part of the AS/SVE performance test. The AS/SVE system underwent a Phase II expansion in 2003. On June 26, 2003, the Phase II AS/SVE system was initiated and fully operational. An ESD was issued on September 8, 2006; to enhance the OU3 remedy with the use of Accelerated Natural Attenuation (ANA). ANA involves the injection of electron donors and possibly adding microbes. The use of ANA should speed up the process of remediating the VOC contamination in groundwater on and around the former Burlington property. Activities conducted at the Site were consistenfwith the original OU1, OU2, and OU3 RODs, the 2006 ROD Amendment for OU1, the 2006 ESD for OU3, and all EPA- approved RD/RA documents. The RD Reports, including a Quality Assurance Project Plan, incorporated all EPA and NCDENR quality assurance and quality control (QA/QC) procedures and protocol. EPA analytical methods are used for all validation and monitoring samples during RA activities. Sampling of soil and water followed the EPA Five-Year Review FCX-Statesvif/e • Statesville, Iredell County, NC • Page 20 protocol USEPA, Region 4, Science and Ecosystem Support Division, Environmental Investigations Standard Operating Procedures and Quality Assurance Manual, May 1996 (EISOPQAM), as revised, and Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods. · The QNQC program developed and used for all three (3) RAs has been comprehensive. All contractors and subcontractors complied with the requirements set forth in the QNQC plans. Therefore, EPA and NCDENR believe the laboratory analyses have been accurate to the degree needed to assure satisfactory execution of the RAs. 4.2 System Operation/Operation and Maintenance EPA's Contractor Roy F. Weston (Weston) originally contracted the O&M to Applied Earth Science (AES). In September 1994, Delta Environmental Consultants (Delta) acquired AES and assumed responsibility for performing O&M at the site, including the semi-annual sampling. The OU1 RA has included the following operation and maintenance (O&M) activities: performing routine maintenance and repairs; weekly groundwater level measurements from the monitoring wells and extraction wells; recording instrument readings; recording flow meter measurements from the extraction wells as well as effluent discharge; collecting influent and effluent samples from the system, and collecting groundwater samples from designated monitoring wells for analysis. Weston submitted quarterly reports to EPA and NC DENR summarizing the sampling data collected during the operation and maintenance of the OU1 groundwater pump-and-treat system. Treated effluent has been discharged into the City of Statesville's sanitary sewer under a discharge permit. As stated in the 1993 ROD for OU 1, the total estimated present worth cost of operating and maintaining the OU1 pump-and-treat system for a 30-year period was $4,161,525. The actual cost of operating and maintaining the system to date exceeds $1,000,000. The OU1 ROD Amendment dated September 2006 changes the OU1 remedy from pump-and-treat to MNA remedy. The total present wqrth of this alternative remedy for the first 5 years is estimated to be $376,912, and the estimated cost for implementing the MNA remedy for 30 years is $674,554. As stated in the 1994 ROD, the OU2 remedy addressed the soil contamination on • the former FCX property. Remedial activities included: excavating and stockpiling contaminated soil; treating the contaminated soil on-Site with thermal desorption and treating the residuals on-Site with Base Catalyzed Decomposition; backfilling the . treated soil into the excavated areas; decontaminating the warehouses; and re- constructing the concrete floors in the warehouses. Five-Year Review FCX-Statesvil/e • Statesville, Iredell County, NC • Page 21 The total amount of soil treated during the OU2 RA was 15,164 tons. The total costs for Roy F. Weston and their subcontractor IR Systems to use thermal desorption to treat 15,164 tons of contaminated soil was $3,571,687.00. Based on these costs, the cost of treating the soil. averaged $235.00 per ton. The extra costs for transporting ' the soil to and from the treatment system, re-hydrate and compact the treated soil into the excavated areas, replace the concrete floors, decontaminate the warehouses, were $1,980,151.00 (as of 09/07/2001). The combined total costs for completing the OU2 RA are $5,551,838.00. The OU3 ROD includes a combination of AS, SVE, and MNA to address voe contamination in soil and groundwater on and around the former Burlington property. Current OU3 O&M activities include semi-annual source area groundwater sampling, as well as MNA sampling to monitor groundwater quality on and around the former Burlington property. Twenty-two MNA wells and thirty-two source area wells were sampled during the most recent sampling event during the Fall of 2005. Three wells associated with the Pre-Design Investigation for ANA were also sampled during the most recent Fall 2005 semi-annual sampling event. During the calendar year 2005, OU3 included the following O&M activities for the AS/SVE system: system checks three times a week; monthly on-Site O&M activities such as sparge well flow adjustments, SVE flow measurements, PCE monitoring of the SVE vapor using Draeger Tubes, and air compressor checks; bi-weekly draining of condensate from the drip traps and liquid separator during periods of cold weather; collection of vapor samples for VOCs in summa canisters from each SVE well and from the blower; change-out of the GAC vessels with re-activated air-treatment carbon; sampling of 32 source area wells in the Spring and Fall of 2005; and: removal and disposal of condensate drained from the AS/SVE system and purge water generated during the sampling events, Also during the 2005 calendar year, OU3 O&M activities included the semi-annual Monitored Natural Attenuation (MNA) sampling, which occurs at the same sampling periods as the AS/SVE groundwater sampling. Pre-design ANA sampling also took place in fall 2005. As stated in the 1996 ROD for OU3, capital costs for the Air Sparging with Active Venting were estimated to be $1,032,500, O&M costs (for an estimated 20 years of operation) of $1,966,940 with a total project cost of $3,030,200. The cost of Soil Vapor Extraction was estimated at $121,250 for capital costs, $955,670 for O&M costs with a total project cost of $1,076,920. However, the ESD signed in 2006 changed the ROD to also include ANA. The ESD will occur in several phases (as needed), the cost for Phase I will be $943,953 for Planning, Design, and Implementation and $283,186 for Administration af!d Contingency with a total estimated ANA Phase I cost of $1,227,139. Five-Year Review FCX-Statesvil/e • Statesville, Iredell County, NC 5.0 Progress Since Last Five-Year Review This is the first Five-Year Review for the Site. 6.0 Five-Year Review Process 6.1 Administrative Components • Page 22 The Five-Year Review process for the Site was performed by the NC DENR, Superfund Section, from January through September 2006. Nile Testerman (Environmental Engineer) and Stephanie Grubbs (Hydrogeologist) from NC DENR were responsible for gathering and reviewing data for this Review. On-site meetings, telephone and/or email discussions/interviews with Ken Mallary (EPA Remedial Project . Manager -RPM), Nancy Prince (EPNG), Ken Oma (Brown and Caldwell), and Maria Megehee (Brown and Caldwell) were conducted. Other activities conducted for this review include document review (see Attachment 1 ), completion of a Site Inspection Checklist (see Attachment 2), community interview documentation (see Attachments 3), and the Five-Year Review Report preparation. 6.2 Community Involvement Once the Five-Year Review has been approved by EPA, a public announcement will be placed in the Statesville Record and Landmark informing the community that the Five-Year Review report is completed, and available for review at the EPA Record Center, 11 th Floor, 61 Forsyth Street, SW, Atlanta, GA, 30303, and the Iredell County Library, 135 East Water Street, Statesville, NC. · 6.3 Document Review This Five-Year Review consisted of a review of relevant documents including the signed OU1, OU2, and OU3 RODs, OU3 ESD, OU1 ROD Amendment, RI/FS Reports, RD/RA Reports, Construction Completion Reports, OU3 AS/SVE Progress Reports, and OU1 semi-annual Groundwater Sampling Reports. Applicable soil and groundwater clean-up standards, and other applicable or relevant and appropriate requirements (ARARs), as listed in the RODs, OU1 ROD Amendment, and OU3 ESD, were also reviewed and checked for updates. See Attachment 1 for a complete list of documents reviewed. · Five-Year Review FCX-Statesville • Statesville, Iredell County, NC 6.4 ARAR Review • Page 23 In performing the Five-Year Review, the ARARs which address the potential risk posed to human health and the environment were reviewed (i.e., addressing the protectiveness of the remedy). This is in kE!eping with current US EPA guidance on five-year reviews. Site-specific groundwater ARARs are identified as follows: Maximum contaminant levels (MCLs) and groundwater standards specified in NCAC 2L are ARARs. Both the original remedies in the OU1, OU2, and OU3 RODs, as well as the amended remedy in the OU1 ROD Amendment and the enhanced remedy in the OU3 ESD, have been designed and implemented to obtain ARARs throughout the entire Site. The Federal and State ARARs identified for the Site include the following: Federal ARARs • 40 CFR Parts 260-271 promulgated under the authority of the RCRA and RCRA as amended (42 USC Section 6921-6939) . • Clean Water Act (CWA 33 USC Sections 1251-1376, 40 CFR Parts 121, 122, 125,Jand 131) · • Occupational Safety and Health Administration (29 USC Section 651 et seq. and 29 CFR 1910, Part 120, 1926.53) • Safe Drinking Water Act ( 42 USC Section 1412, 40 CFR Part 141) • Clean Air Act (40 CFR Part 50, Part 60, Subpart A and Subpart B, and Part 61, USC 1857) • Clean Water Act, Discharge Limitations (33 USC Section 1311, 40 CFR Part 122,125, 129, 133, 136) • CWA Pretreatment Standards (33 USC Section 1317); 40 CFR 403.5 • Department of Transportation Hazardous Material Transportation Act (49 USC Sections 1801-1812; 49 CFR Parts 107, 171-179) • Clean Air Act (40 CFR Part 50, Part 60, Subpart A and Subpart B, and Part 61, use 1857) • Clean Air Act (42 USC 109; 40 CFR Part 61) • Fish and Wildlife Coordination Act (16 USC 661-666) • Floodplain Management Executive Act (Executive Order 11988; 40 CFR 6.303) StateARARs • North Carolina Solid Waste Disposal Regulations (North Carolina Administrative Code (NCAC), Title 15A, Chapter 138) Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Page 24 • Regulations for the Management of Hazardous Waste promulgated under the authority of the NC Waste Management Act (NCAC Title 15A, Chapter 13A) • NC Drinking Water and Groundwater Standards; Groundwater Classifications and Standards (NCAC Title 15 Chapter 2L) • NC Surface Water Quality Standards (NCSWQS) Classification and Water Quality Standards (NCAC Title 15A Chapter 2B) • NCSWQS Technology-Based Effluent Limitations (NCAC Title 15A Chapter 2, Subschapter 2B.0400) • NC Drinking Water Act (General Statutes Chapter 130A, NCAC 311- 327) • NC Air Pollution Control Regulations (NCAC Title 15A Chapter 2D and 20) • NC Water Pollution Control Regulation Wastewater Discharge to Surface Water (NCAC Title 15, Chapter 2, Subchapter 2H) • NC Sedimentation Control Rules (NCAC Title 15A Subchapter 4) 6.5 Data Review In addition to performing O&M activities, the subcontractors also perform semi- annual sampling. These sampling events include collecting samples from twelve on- Site and six off-Site monitoring wells and the influent and effluent to the OU 1 pump and treat system. Based on the most recent L TRA, April 2005 Semi-Annual Sampling Event Report (November 2004 through April 2005), Weston and the subcontractors began the sampling event the week of April 27, 2005. The eighteen wells were purged and sampled for organics, pesticides, PCBs, and total metals. Figure 3 shows the locations of all groundwater monitoring wells at the Site, including the 18 wells sampled. during the OU1 sampling event. The following is a summary of the VOC data collected during the most recent sampling event: • 1, 1-dichloroethane (1, 1-DCA) was de.tected at concentrations ranging from 1.7 ug/I to 11 ug/l in MW-1, MW-2, MW-5, and W-29 exceeding ROD remediation goal of·1 ug/I; • Chloroform was detected at concentrations ranging from 0.5 ug/I to 1.1. ug/I in MW-1, MW6s, and W-27, exceeding ROD remediation goal of 0.19 ug/I; Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 25 Figure 2: Site-Wide Groundwater Monitoring Well Locations ! ::-:: .i ', ,·-., ., -.. ; {: ' .. / ·- Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 26 • PCE was detected at concentrations ranging from 11 ug/I to 49 ug/I in MW-1, MW-2, MW-5d, MW-6d, MW-11, and W-29, exceeding the ROD remediation goal of 0.7 ug/I; and • TCE was detected at concentrations ranging from 2.9 _ug/I to 6.7 ug/I in MW-2, MW-5d, MW-6d, MW-11, and W-29, exceeding ROD remediation goal of 2.8 ug/1. The remaining voes (1, 1-dichloroethene (1, 1-DCE), chloromethane, and bromodichloromethane), as well as the compound bis(2-ethylhexyl)phthalate, were not detected in any of the monitoring wells at concentrations exceeding the groundwater remediation goals. The following is a summary of the pesticide data collected during the most recent OU1 sampling event: • Alpha BHC was detected at concentrations ranging from 0.12 ug/I to 1.44 ug/I in MW-1, MW-2, MW-3, MW-5d, MW-5s; MW-6s, and MW-9, exceeding the ROD remediation goal of 0.01 ug/I; • Beta-BHC was detected at concentrations ranging from 0.0.055 ug/1 to 0.39 ug/I in MW-1, MW-2, MW-3, MW-5d, MW-5s, and MW-9, exceeding the ROD remediation goal of 0.01 ug/I; i · • Gamma-BHC was detected at concentrations ranging from 0.056 ug/I to 0.16 ug/I in MW-1, MW-2, MW-5d, and MW-5s, exceeding the ROD remediation goal of 0.027 ug/I; • · Gamma chlordane was detected-at a concentration of 0.082 ug/I MW-3, exceeding the ROD remediation goal of 0.027 ug/I; and • The other pesticides-listed as COCs for the Site, dieldrin and heptachlor epoxide, were not detected in any monitoring wells at concentrations exceeding their respective remediation goal. '.,_.• .. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 27 The following is a summary of the metals data collected during the most recent OU1 sampling event: · · · • Chromium was detected at a concentration of 62 ug/I in MW-5s, and 56 ug/I in MW-10, exceeding the ROD remediation goal of 50 ug/I; • Manganese was detected at concentrations ranging from 41 ug/I to 1,700 ug/I in all monitoring wells, except for MW-3, MW-4, and W-5d, exceeding the ROD remediation goal of 50 ug/I; • The other metals listed as COCs in the 1993 ROD, beryllium and vanadium, were not detected in any monitoring wells at concentrations exceeding their respective remediation goals. Despite the fact that chromium and manganese have been identified in a few on- Site monitoring wells at levels exceeding the groundwater remediation levels, EPA and NC DENR have determined that these metals are not Site-related constituents. For this reason, the metals have been removed as COCs from the OU1 remedy, and will not be addressed during the amended OU1 remedy. Since 1998, influent/effluent samples have been collected and analyzed from the pump-and-treat system to ensure compliance with the City of Statesville Discharge Permit. Analytical results from the January 2005 and April 2005 sampling events indicate VOCs or.pesticide levels in the system's effluent were below the detection limits. This data indicates that the OU 1 pump-and-treat system is effectively treating the contaminated groundwater prior to being discharged to the city POTW. Using the data from the April 2005 semi-annual sampling event, a trend analysis was developed by Weston to determine if the levels of pesticides and voes in groundwater have been decreasing on the former FCX property and south thereof over the past 5 years. The trend analysis showed a general trend of decreasing pesticide and VOC concentrations in monitoring wells located on the former FCX property and south thereof. The.analysis also indicated the number of groundwater monitoring wells with pesticide contamination has decreased, indicating the extent of pesticide contamination in groundwater at the former FCX property and south thereof has been reduced in the past 5 years. The general trend of decreasing pesticide and VOC concentrations on the former FCX property and south thereof may be partially due to the successful remediation of pesticides in soil during the OU2 Remedial Action, and the reduction of VOCs in soil and groundwater during the OU3 Remedial Action. Using the analytical data from the influent sampling, the mass of contaminants removed from the groundwater was calculated. Since the start-up of the OU1 groundwater pump-and-treat system in 1998, Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 28 a total of 0.49 pounds of pesticides, and 47.28 pounds of voes, have been removed. In October 1998, instead of demolishing the warehouses, EPA decided to leave the warehouses intact during the OU2 soil remediation. Leaving the warehouses intact provided the dry space needed for stockpiling the contaminated soils following excavation. A fifty by fifty foot grid was established within each area where contaminated soil was excavated. Once the soil was excavated, soil samples were . collected from the sidewalls and bottom of the excavated areas in order to confirm that all soil exceeding the remediation levels was excavated. Immunoassay kits were used to achieve real-time analysis on the soil samples. With a few exceptions, all of the areas with pesticide soil contamination exceeding the soil remediation levels were excavated. Figure 3 shows the OU2 excavation areas. A few sample locations with soil contamination above the remedial goals were intentionally not excavated in order to maintain the structural integrity of the warehouses, and to ensure the safety of the workers (i.e., two locations within the Upper Warehouse and one location within the Lower Warehouse). The soil that remained at these locations, although above the remedial goal for total pesticides of 1 ppm, contain less than 15 ppm of the pesticide DDT, and should naturally attenuate over time. Beginning in February 2000, IR Systems mobilized the thermal treatment equipment, including the installation of thermal oxidizers. Full-scale thermal treatment of the soil was initiated after stack testing and ambient air monitoring was successfully completed. The thermal treatment process at the former FCX property included the following steps: pre-treated soils were loaded into the soil treatment trays; the trays were leveled and loaded onto the treatment chamber's infrared heater base; the.hood containing the manifold assembly of the treatment system was ttien lowered onto the treatment trays creating an airtight seal; and a vacuum fan was then started and the target chemicals were heated to their reduced boiling point and/or significant vapor pressure. Within the treatment system air emissions control system, the carrier gas (air) passed through a condensing system (an activated carbon bed) and an oxidizer prior to final discharge to the atmosphere. Condensate was collected during the treatment process, and separated for BCD treatment of the residual liquid. Other OU2 activities included spraying the soil in the excavation and stockpile areas with water to ensure dust emissions were kept to a minimum. Soil sampling was conducted on stockpiled soil after treatment prior to be backfilled into the excavation areas. Total pesticide concentrations ofthe treated soil ranged from 0.0 ppm to 1.15 ppm, with the average total pesticide concentration being 0.321 ppm. The four stockpiles with total pesticide concentrations slightly above the 1 ppm total pesticide or 3.2 ppm pentachlorophenol remediation level were blended with other stockpiles with lower total pesticide concentration in order to achieve an average total pesticide or 7 Five-Year Review FCX-Statesvifle • Statesville, Iredell County, NC • pentachlorophenol concentration below the remediation levels. Page 29 On June 13, 2001, once all the thermal treatment process was completed, and the concrete floors were re-poured over the excavation areas, Weston conducted a warehouse wipe sampling investigation. The purpose was to determine if total pesticide or pentachlorophenol surface contamination existed on the ceiling and walls of the warehouses. Although the analytical results of the wipe samples indicated total pesticide and PCP concentrations did not represent a human health risk, the warehouses were pressure-washed to remove dust. A trench was constructed around the backfilled excavation areas to capture the water from the pressure-washing process. Once the pressure-washing was completed, all water and soil from the trench was either excavated or treated on-Site. The OU3 remedy includes the use of AS/SVE in areas located on the former Burlington property with higher levels of VOCs in soil and groundwater, and MNA for remediation of groundwater in areas located on and around the former Burlington property with lower levels of VOCs. The MNA portion of the OU3 remedy began in 1998, while the active source remediation began in July 2001 with the startup of th_e SVE system. In 2003, the AS/SVE system was modified and upgraded by adding new AS, SVE, and monitoring wells. The upgraded AS/SVE system has operated since June 2003, except for occasional shutdowns for sampling events, maintenance, and in response to system alarms. The following summary and conclusions are from the OU3 AS/SVE Progress Report for Calendar Year-2005, prepared by Brown and Caldwell for El Paso Natural Gas Company: • the OU3 remedy has involved the use of MNA since 1998 to address the areas on and around the former Burlington property with lower voe concentrations. The primary COCs are tetrachloroethene (PCE) and its daughter products, including TCE and cis-1,2-dichloroethene (cis-DCE); • Since AS/SVE operations began.in 2001, the total amount of PCE removed from the source area is approximately 6,140 kg; and • Based on the PCE removal rates over the past few years, EPNG anticipates the AS/SVE system may be less beneficial in the future. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC Figure 3: OU2 Excavation Areas C I I ( Page 30 z 0 ~ (..) X w N ::::, 0 (/) I~- M 0::: ~<l:'. :, .Ql LL ~ 8 : I ~ ;;; 'i ~ ~i ~~ _J Five-'(ear Review FCX-Statesville • Statesville, Iredell County, NC • Page 31 The 2006 ESD for OU3 adds ANA to the existing AS/SVE/MNA remedy. ANA involves the injection of electron donors and microbes into the aquifer to accelerate the natural attenuation of the VOCs. The ANA should speed up the remediation of the voes on and around the former Burlington property. A Pre-Design Investigation (POI) was conducted by Brown and Caldwell in 2005 to obtain data to assist in the preparation of designing the ANA portion of the OU3 remedy. The POI included the following: evaluating the microbial community in the groundwater on and round the former Burlington property; testing injection well construction methods; conducting a geophysical logging survey; and collecting groundwater and soil vapor samples. The POI report was submitted to EPA and NC DENR for review in January 2006. The conclusions and recommendations from the POI report include the following: • a transition zone exists at the base of the regolith where saprolite grades into bedrock; the transition zone appears to exist throughout the study area; • the presence of microorganisms in the study area supports the concept of using ANA during the OU3 remedy (i.e., adding electron donors to stimulate enhanced reductive dechlorination); • the majority of the voes detected were PCE and its daughter products, TCE and cis-DCE; • the ratio of cis-DCE to PCE in groundwater samples, as well as the presence of vinyl chloride and ethane, provides direct evidence that the appropriate degradation processes are proceeding; • a recommendation was made to perform a focused feasibility study to select the Phase I electron donor, begin the design for the Phase I electron donor injections, and following the US EPA and NCDENR approval of the Phase I design, perform the Phase I injections oMhe elected donors and associated groundwater monitoring. Brown and Caldwell completed and submitted Fall 2005 Semi-Annual Groundwater Sampling for OU3 in May 2006. This report includes the most current MNA sampling conducted during the OU3 remedy, which occurred in October 2005. Figure 4 shows the locations of the source area wells. Table 6 is a summary of the MNA wells sampled during the Fall 2005 event, and Figure 5 shows the locations of the wells sampled for MNA parameters. Table 7 is a summary of the source area wells sampled during the Fall 2005 event. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Figure 4: OUJ Source Area Well Locations Page 32 1 l , i:l'1f 1 I I I I I l ll I 1 Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Table 6: List of MNA Wells Sampled in Fall 2005 Tabk 2.1. MNA Monitoring Wells for Semiannual Groundwater Sampling" FCX~Statcsville Supcrfund Site OU3 Groundwater Monitoring Zooc Wellb Comments for Fall 2005 Sampli.ag Eve,:i.1 Nonh An::a.: Shallow: W-6s• W-7s Well WH 00l sampled becau.se of umuficictH water: W-Ssd W-!01• W-12.t• Well w:u no! 11mpled because it wu dry. W-171 Only VOC., TOC, and MEE s:amplcs wctc collected due 10 insuf6ci=nt water volume. · W-18s• W-191 Colleercd enn volume fo1 MS/MSD. W-201 W-31s Ulti:m:iedatc: W-Bi• W-10i' Collected equipment blank-W-PA. W-12i• W-20i W-20d Deep w,ill. W-28i W-lOi Collected illl'llytic:U duplicate -W-PB. W-3\i South Aica: Shallow: W-.ls< W-55 W-24s Intermediate: W-Si W-29i W-32i • The u,o.lytic:ll methods for the :,nt.Jysu of gmuodvn.~ nmplcs ore given in T,blc 2-} ·-Monitoring wells sdc,:~ for snnwln~ gfOUDd=tcr so.mpling :uc from the li11 in Table •-1 of the "Remci:ful Action Wod< Piao fot Opcnblc Unir Three, FCX•SutuYille, Si:perfund Sire, Stmtvi!Je, North Cuolina" ~md July 2000 by B,""'n and Caldwdl with wrne modifi.alions. SQu,cc unwell W.17,;, not routindy sampled due to low waler lcveli Other source un wells that ue put of the AS/SVE ,ym:m uc being sampled routinely Other rno<lifint1on1 uc indic,,n:d in the comments or footll<Kel • Wcll is not omong tho:sc rh>.t uc rou!mely nmpled fo, um.ia,:,.ouLI ntrunl anmuo.tion p=ctc:n •w.e. wu sampled u an o.ltemale oatunl mmu:1.tioo background well ,ince W•l 2• wu dry • N"llrU<al attc11uatio11 background well P.\l'ROJ\El Puo\E.l'NG f0C\1J9096\00S-OO◄\F• OJ ll'l"'rt\t020! do, Page I of I Page 33 Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Fi ure 5: OU3 MNA Well Location Ma Page 34 i -e llooj,·~1~1\r.'l~!>lod-~ J • • Five-Year Review Page 35 FCX-Statesville Statesville, Iredell County, NC Table 7: List of Source Area Wells Sampled in Fall 2005 Table 2-2. Sowc::c Arca Monitoring Wells for Semiannual Groundwater Sampling• FCX-Statesvillc Supcrfund Site OU3 Cwnot Prrn<>u, Phase II Phue l Well Function Well ID wenm Comm,:rm fo1 Fall 2005 S:lmpling Event AS/SVE EW-1/SW-l EW-1/SW-1 EW-2/SW-2 EW-2/SW-2 EW-4/SW-4 EW_.. EW-17/SW-17 MP-14 EW-23/SW-23 Ph.uc II well inm.lled in 2003: SVE EW-3 EW-J EW-5 EW-S EW-6 EW-6 EW-7 EW-7 EW-8 EW-8 EW-9 EW-9 EW-10 EW-10 EW-1! !'-JP-12 EW-12 Phase TI well installed i.a 2003 EW-!3 MP-13 EW-14 MP-5 EW-15 Phue II "1dl installed in 2003, EW-16 MP-11 EW-18 Phase II well insuJled in 2003 Collec!cd cxtn volume for MS/MSD EW-19 Phase lJ well insulled in 2003. Collected duplicate EW-JB Collecied equipment bl~ EW-JA. EW-20 MP-10 EW-21 MP-9 EW-22 MP6 Collecu:d extra volume for MS/MSD. EW-24 MP-2 Monitoring Probe MP-I MP-I Collected equipment blank MP-JC. MP-3 MP-3 MP-4 Ml'-4 MP-7 MP-7 MP-8 t.fP-8 MP-15 MP-15 MP-16 Phue II well i.nst>lled in 2003. MP-17 Phase n we□ Untalled in 2003, Collected duplicare MP-JD. • An:alyrial method1 fo, rhe :walyscs of gioundwo.ttr umpk1 :i..e given in. Tobi,: 2-3. Sou«:• ueo gmundw,rer Hmples were subject to field mcuu,emenrs ind l:abomory •n>lyN for Target Compound List (TCL) voe. P-\1'11,0)\EI p...,\EPNC FCX\U'Mi96\llOS.tlCM\Fall OS lopon\10201cloc Page 1 of I Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 36 Figure 6: PCE Shallow lso-concentration Map for OU3 Source Area k I :: : .. -.-~ ----=: I -,• ; C, :J\~ ; 1· l _.!_-=. --•ICOf"<l-'"111 I ;j If I . -' ' ' j ' ,. The following conclusions were drawn from the Fall 2005 Semi-Annual I Five-Year Review FCX-Statesville • Page 37 Statesville, Iredell County, NC Groundwater Sampling Report for OU3, FCX-Statesville Superfund Site, prepared by Brown and Caldwell for El Paso Natural Gas Company: • At the boundaries of the VOC plume, voe concentrations remain near or below detection limits. A plume that is not'expanding is an indication that natural attenuation is occurring. Of the 21 MNA wells sampled, 18 showed no apparent concentration trends in recent years, two wells (W-8i to the west and W-29i to the south) showed likely downward trends, and one well (W-20s to the north) shows a possible upward trend. Figure 7 is the most recent PCE Shallow lso- concentration map for the source area. • Primary and secondary evidence supports the occurrence of natural attenuation in groundwater on and around the former Burlington property, including reductive de-chlorination; · ' ' 6.6 Site Inspection The Site inspection was conducted on April 11, 2006. The following individuals attended the inspection: • • • • • • Ken Mallary, RPM, US EPA Nile Testerman, Environmental Engineer, NC DENR, Superfund Section Ken Oma, Project Manager, Brown and Caldwell Nancy Prince, Project Manager, El Paso Natural Gas Company Maria Magehee, Principal Scientist, Brown and Caldwell Elizabeth Blalock, Site Safety Manager, Brown and Caldwell During the inspection, all on-Site documents and records were·noted as readily available and up-to-date. According to the US EPA, institutional controls such as deed and land use restrictions are in place on the former Burlington Industries property (OU3). El Paso Natural Gas Company has placed a restrictive covenant on the former· Burlington property. Institutional controls such as deed restrictions do not currently exist on the former FCX property; however, institutional controls will be placed on the former FCX property once it is resold. All of the monitoring wells on th.e former FCX and former Burlington properties are locked and secure. Gates onto both properties are locked, and access to the general public is prohibited. All O&M records for the OU1 and OU3 remedies are up-to-date and available. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC 6. 7 Interviews • Page 38 The following persons were interviewed regarding the activities and implementation of the remedial actions at the FCX-Statesville site. Only a portion of the interviews are stated below, for the complete interview statement see Attachment 3. Ken Mallary, EPA RPM: Overall impression of the project, 'Since 1998, the OU1, OU2, and OU3 Remedial Actions have not only reduced the amount of source contamination at the Site,· . but reduced the potential risks to the human population living around the Site. " Nancy Prince, Representative, El Paso N_atural Gas Company: Overall impression of the project, "No comment." However, EPNG did provide comments to EPA during the public comment period for the OU 1 ROD Amendment. Refer to the Appendix B of the ROD Amendment for those comments. 7.0 Technical Assessment 7.1 Question A: Is the remedy(s) functioning as intended by the decision documents? With the signing of the OU1 ROD Amendment in September 2006, the OU1 remedy on the former FCX property and south thereof will change from groundwater pump-and-treat to MNA. The total present worth of the MNA remedy for the first 5 years is $376,912. The estimated cost for implementing the MNA remedy for 30 years is $674,554. The MNA will effectively reduce groundwater contaminants since the source area has been remediated. With the signing of the OU3 ESD in September 2006, the existing OU3 remedy will be enhanced with ANA. The remedial activities for OU2 are completed at the Site. OU2 RA activities included excavation of contaminated soil in and around the existing warehouses; excavation and stockpiling the pesticide-contaminated soil inside the existing warehouses; construction of the thermal desorption system; thermal treatment of the soil; Base Catalyzed Decomposition (BCD) treatment of the liquid residual resulting from the thermal treatment of the soil; backfilling of the treated soil into the excavation areas; decontamination of the warehouses; and reconstruction of the concrete floors inside the warehouses. All stockpiles had post-treatment total pesticide and PCP concentrations that were below the detection limit except for four stockpiles. One of these four stockpiles with PCP concentrations exceeding the 3.2 ppm remediation level was blended with another stockpile with a lower average PCP concentration in order to achieve the remediation level. The remediation levels for total pesticides and PCP in the treated soil were achieved during the OU2 RA. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 39 The OU3 remedy has been reducing VOC concentrations in soil and groundwater in most of the source area. Since AS/SVE operations began in 2001, voe concentrations in portions of the source area have decreased, but have stabilized or increased in other portions of the source area. AS/SVE appears to have had little or no effect on the voe concentration in the northern portion of the source area. Based on the current trend and mass VOC removal rates, it is anticipated that the AS/SVE will become less beneficial in the future. The OU3 plume appears to be stable. At the boundaries of the plume, VOC concentrations remain near or below detection limits. Institutional controls are currently being implemented as part of the OU3 remedy. These controls include a restrictive covenant on the former Burlington property to prohibit the use of groundwater. EPNG also checks with the City of Statesville twice a year to ensure no one is using private wells within the area with Site-related groundwater contamination. The Bankruptcy court permitted FCX to abandon the property in the 1980s. To date, the former FCX property remains abandoned. EPA has informed prospective purchasers of the former FCX property that an institutional control such as a restrictive covenant needs to be implemented. An ESD was issued in September 2006 to enhance the OU3 remedy with the use of ANA. ANA involves the injection of electron donors and microbes into the aquifer to accelerate natural attenuation. The ESD will occur in several phases, the cost for Phase I will be $943,953 for Planning, Design, and Implementation and $283,186 for Administration and Contingency, with a total estimated ANA Phase I cost of $1,227,139. 7.2 Question B: Are the exposure assumptions, toxicity data, clean-up levels and remedial action objectives (RAOs) used at the time of the remedies still valid? The exposure assumptions, toxicity data, clean-up levels, and RAOs used at the time of the remedy are still valid. Likewise, with a few exceptions, the chemical-specific ARARs (i.e., MCLs and the State Groundwater Standards) have not'changed from the Remediation Goals given in the RODs, ROD Amendment, or ESD. With the signing of the OU1 ROD Amendment in September 2006, a few chemical-specific ARARs have changed from the 1993 OU1 ROD to the amended MNA remedy. These changes include the State's groundwater standard for total chlordane, .10 ug/I, which is now being used for the amended remedy instead of using a separate cleanup level of .027 ug/1 for alpha-chlordane, and .027 ug/1 for gamma-chlordane. In addition, due to the difficulty in monitoring pesticide levels in groundwater below the contract quantitation limit, the contract quantitation limit for the pesticides heptachlor- epoxide and lindane, .05 ug/1 and .20 ug/1 respectively, will be used instead of the cleanup levels established in the 1993 ROD. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 40 With the signing of the ESD in September 2006, a few chemical-specific ARARs have changed from the 1996 OU3 ROD to the enhanced OU3 remedy. These changes include the following: the remediation level for carbon tetrachloride changed from .30 ug/I to .269 ug/I, chloroform changed from .19 ug/I to 70 ug/I, 1,2-dichloropropane changed from .50 ug/I to .51 ug/I, and methylene chloride changed from 5 ug/I to 4.6 ug/1. In the OU2 ROD, RAOs were established for soil to prevent direct contact exposure to soil containing elevated levels of Site-related contaminants, and to minimize the potential for infiltration of pesticides from the soil into the groundwater. With the exception of three (3) locations beneath the exterior walls of the warehouses with levels of total pesticides above the 1 ppm remediation level, all remediation goals were achieved during the remedial action for soil. See page 31 of this document for further explanation. There have been no changes in the physical conditions of the Site that would· affect the protectiveness of the OU1, OU2, or OU3 remedy. With the signing of the OU1 ROD Amendment and the OU3 ESD both dated September 2006, the physical nature of the OU1 and OU3 remedies will change in the near future .. Although these remedies will change, no physical site conditions, new human health or ecological routes of exposure, or contaminant characteristics have changed that would affect the protectiveness of either remedy. With the exception of a few remediation levels changing in the OU1 ROD Amendment and OU3 ESD, all existing applicable chemical-, action-, and location-specific requirements in the OU1 and OU3 ROD will not change (see OU1 ROD Amendment and OU3 ESD for changes). 7,3 Question C: Has any other information come to light that could call · into question the protectiveness of the remedy? No additional information has come to light that could call into question the protectiveness of the remedy. 7.4 Technical Assessment Summary The OU1 and OU3 groundwater remedies are functioning as intended, and the OU2 soil remedy was successfully completed in 2001. However, since 2001 when the AS/SVE portion of the OU3 remedy began in the source area, voe concentrations in some source area wells have decreased, while voe concentrations in other source area wells have stabilized or increased. Based on the varying concentrations of voes in the source area, and the mass removal rates of voes in the source area, the expectation is that AS/SVE will become less beneficial for treating voes in the source area in the future. The addition of ANA to the OU3 remedy should enhance the natural Five-Year Review FCX-Statesville • Statesville, Iredell County, NC • Page 41 degradation of VOCs, thereby speeding up the remediation of voes in groundwater on and around the former Burlington property. Groundwater data collected during the OU3 remedy does show that the natural attenuation of voes is occurring on and around the former Burlington property. With the signing of the OU1 ROD Amendment and OU3 ESD, changes will occur in the OU1 and OU3 remedies. The exposure assumptions, toxicity data, clean-up levels, and RAOs for the OU1 and OU3 remedies are still valid. s·ection 7.2 of this Five-Year Review also describes a few groundwater remediation levels that have changed with OU1 ROD Amendment and OU3 ESD. No other information has come to light that could call into question the protectiveness of the remedies. Groundwater monitoring will continue during the OU1 and OU3 remedies in order to evaluate the progress being made towards accomplishing the groundwater remediation levels. In order to verify that protection of human health and the environment is maintained in the future, five-year reviews will be conducted until the groundwater remediation levels have been reached. An institutional control such as a restrictive covenant will be implemented on the former FCX property once it is sold to prohibit the use of groundwater for potable purposes. The lack of institutional controls on the former FCX property does not affect the protectiveness of the OU1 remedy since there are no groundwater users in the affected area. 8.0 Issues One issue has been identified during this 5-Year Review .. • The selected remedy in the OU1 ROD dated September 1993 provides for the remediation of contaminated groundwater on the former FCX property and _south thereof. The ROD specified the use of deed restrictions in the affected area to prohibit the consumption of Site-related groundwater contamination. EPA has determined that institutional controls such a deed notice and restrictive covenant should be placed on the former FCX property in the future when the property is sold. In addition, consistent with the City of Statesville's Ordinance Municipal Code Chapter Utilities, Article VII. Water and Sewer Connections, Section 23-276 (a), City, County, and State officials will be contacted twice a year (consistent with the OU3 remedy) to make sure no one gets permission to install a drinking water well and/or use a drinking Water well within the area known to be affected by Site-related groundwater contamination. The former FCX property and the former Burlington property are both fenced, and access to the general public is prohibited. Five-Year Review FCX-Statesville • Statesville, Iredell County, NC 9.0 Recommendations and Follow-up Actions • Table B:. Recommendations and Follow-up Actions Issues Recommendations/ Follow-Party Oversight Milestone up Actions Responsible Agency Date Institutional EPA has determined that EPA, State, EPA& September controls on the institutional controls such as a City, and State 25, 2011 former FCX deed notice and restrictive County property. covenant should be placed on the officials with former FCX property when the cooperation of ' property is resold prohibiting the land owners use of groundwater for potable purposes. The City should also be contacted twice a year (consistent with OU3 remedy) to ensure no one has Violated the City Ordinance (Municipal Code Section 23-276) which requires· connection to City water mains or permission from County Health Department to install a well. Proceed with With the signing of the OU1 ROD PRP, EPA, & EPA& ·September the new Amendment and OU3 ESD in State State . 28, 2011 modified September 2006, the future remedies for remedial activities at the Site will OU1 and OU3. include the implementation of the revised OU1 MNA remedy and the enhanced OU3 remedy Page 42 Affects Protectiveness? ,Y/N) Current Future N y N y Five-Year Review FCX-Statesvi/le Statesville, Iredell County, NC 10.0 Protectiveness Statement • Page 43 The OU1, OU2, and OU3 soil and groundwater remedies at the FeX-Statesville Site are currently protective of human health and the environment in the short-term for the following reasons: • levels of pesticides and voes in groundwater on the former Fex property and south thereof have been significantly reduced during the OU1 Remedial Action to levels approaching the State and Federal Drinking Water Standards; · • levels of total pesticides in soil on the former Fex property were reduced to the 1 ppm remediation level during the OU2 Remedial Action; likewise, levels of pentachlorophenol were reduced to the 3.2 ppm remediation level during the OU2 Remedial Action; • levels of voes in soil and groundwater on and around the former Burlington property have been significantly reduced during the OU3 Remedial Action; • the future implementation of the OU1 MNA remedy on the former Fex property and south thereof will continue to provide protection of human health and the environment; and • the addition of ANA to the existing OU3 remedy on and around the former Burlington property will continue to provide protection of human health and the envi~onment. In addition, no human or ecological exposure pathways exist to contaminated soil or groundwater at the Site. Institutional controls will be implemented as part of the OU1 and OU3 remedies to ensure long-term protection of human health and the environment at the Site. 11.0 Next Review The next Five-Year Review for the FeX-Statesville site is required to be completed within five years from the EPA Region 4 Waste Management Division Director's signature/approval date of this document (September 28, 2011 ). • • ATTACHMENT 1 List of Documents Reviewed Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC • • List of Documents Reviewed FCX-Statesville Site Five-Year Review Five-Year Review FCX-Statesville Statesville, Iredell County, NC U.S. Environmental Protection Agency, Region IV. October 1992. Phase I Remedial Investigation Report, FCX-Statesville Superfund Site, Statesville, North Carolina. U.S. Environmental Protection Agency, Region IV. September 1993. Record Of Decision, Operable Unit One, FCX-Statesville Superfund Site, Statesville, North Carolina. Roy F. Weston, June 1994. Feasibility Study for Operable Unit Two, FCX-Statesville Superfund Site, Statesville, North Carolina. U.S. Environmental Protection Agency, Region IV. November 1994. Record of Decision, Operable Unit Two, FCX-Statesville Superfund Site, Statesville, North Carolina. U.S. Environmental Protection Agency, Region IV. September 1996. Record of Decision, Operable Unit Three, FCX-Statesville Superfund Site, Statesville, North Carolina. Roy F. Weston, January 1999. Remedial Action Report, Operable Unit One Groundwater Remediation, FCX-Statesville Superfund Site, Statesville, North Carolina. U. S. Environmental Protection Agency, Region IV. September 2001. Preliminary Close-Out Report, FCX-Statesville Superfund Site, Statesville, North Carolina. Roy F. Weston, October 2001. Remedial Action Repcirt, Low Temperature Desorption and Base Catayzed Decomposition Treatment of Pesticide and Pentachlorophenol Impacted Soil, FCX-Statesville Superfund Site, Statesville, North Carolina. Brown and Caldwell, December 2003. Construction Completion Report for the Phase II Air Sparging and Soil Vapor Extraction System, FCX-Statesville Superfund Site, Statesville, North Carolina. Weston Solutions, Inc., July 2005. Update of Monitored Natural Attenuation Evaluation, Operable Unit One, FCX-Statesville Superfund Site, Statesville, North Carolina. Weston Solutions, Inc., September 2005. Long Term Response Action April 2005 Semi- Annual Sampling Event Report, Operable Unit One, Groundwater Remediation, FCX- Statesville Superfund Site, Statesville, North Carolina. · • • Five-Year Review ·FCX-Statesville Statesville, Iredell County, NC Brown and Caldwell, October 2005. Spring 2005 Semi-Annual Groundwater Sampling Report, ·Operable Unit Three, FCX-Statesville Superfund Site, Statesville, North · Carolina. Brown and Caldwell, January 2006. Pre-Design Investigation Report for Accelerated Natural Attenuation, Operable Unit Three , FCX-Statesville Superfund Site, Statesville, North Carolina. Brown and Caldwell May 2006. Fall 2005 Semiannual Groundwater Sampling Report, Operable Unit Three, FCX-Statesville Superfund Site, Statesville, North Carolina. Brown and Caldwell May 2006. AS/SVE Progress Report for CY-2005, Operable Unit Three, FCX-Statesville Superfund Site, Statesville, North Carolina. U. S. Environmental Protection Agency, Region IV. August 2006. Explanation of Significant Difference, Operable Unit Three, FCX-Statesville Superfund Site, Statesville, North Carolina. U. S. Environmental Protection Agency, Region IV. August 2006. Final Amendment to the 1993 Record Of Decision for Operable Unit One, FCX-Statesville Superfurid Site, Statesville, North Carolina. • • ATTACHMENT 2 Site Inspection Checklist Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC • • Five-Year Review FCX-Statesville Statesville, Iredell County, NC Five-Year Review Site Inspection Checklist Please note that "O&M" is referred to throughout this checklist. At sites where Long-Tenn Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while being remediated under the Superfund program. I. SITE INFORMATION Site name: FCX Statesville Date of inspection:, 11 April 2006 Location and Region: Statesville, NC Region IV EPA ID: NCD 095458527 Agency, office, or company leading the five-year Weather/temperature: Fair/70 review: NCDENR Remedies Includes: (X) all that apply 0 Landfill cover/containment X Monitored Natural Attenuation D Access controls D Groundwater containment X Institutional controls 0 Vertical barrier walls X Groundwater pump and treatment D Surface water collection and treatment X_Other: excavation, Thermal Desorption (OU2); Air Sparging & Soil Vapor Extraction (OU3) Attachments: 0 Inspection team roster attache</ 0 Site map attached II. INTERVIEWS (Check all that apply) I. O&M site manager Ken Oma (OU3 l Project Manager 11 Apr 2006 Name Title Date Interviewed D at site D at office D by phone Phone no. Problems, suggestions; D Report attached None 2. O&M staff Elizabeth Blalock Site Safet~ Mananger 11 Apr 2006 Name Title Date Interviewed X at site Oat office D by phone Phone no. Problems, suggestions; 0 Report attached None • . • Five-Year Review FCX-Statesville Statesville, Iredell County, NC 3. Local regulatory authorities and response agencies (i.e., State and Tribal offices. emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply. I Agency Contact Name Title Date Phone no. Problems; suggestions; D Report attached Agency Contact Name Title Date Phone no. Problems; suggestions; D Report attached Agency Contact Name Title Date Phone no. Problems; suggestions; D Report attached Agency Contact Name Title Date Phone no. Problems; suggestions; D Report attached 4. Other interviews (optional) 0 Report attached. Ken Mallary-EPA Nancy Prince-PRP, El Paso Maria Megehee-PRP Contractor, Brown & Caldwell I. 2. 3. 4. 5. 6. 7. 8. 9. 10. • • Five-Year Review FCX-Statesville Statesville, Iredell County, NC Ill. ON-SITE DOCUMENTS & RECORDS VERIFIED (X) all that apply O&M Documents 0O&M manual X Readily available X Up to date 0 NIA 0 As-built drawings X Readily available X Up to date 0 N/A 0 Maintenance logs 0 Readily available 0 Up to date 0 N/A Remarks Site-Specific Health and Safety Plan X Readily available 0 Up to date 0 NIA X Contingency plan/emergency response plan X Readily available 0 Up to date 0 NIA Remarks O&M and OSHA Training Records X Readily available X Up to date 0 NIA Remarks Permits and Service Agreements 0 Air discharge permit 0 Readily available 0 Up to date x NIA 0 Effluent discharge D Readily available 0 Up to date x NIA 0 Waste disposal. POTW X Readily available D Up to date NIA D Other permits 0 Readily available 0 Up to date. 0 NIA Remarks OU 1 11um11-and-trea1 sxstem has discharge 11ermit to Citx of Statesville ·s POTW Gas Generation Records 0 Readily available 0 Up to elate 'X NIA Remarks Settlement i\lonument Records D Readily available 0 Up to date X NIA Remarks Groundwater Monitoring Records 0 Readily available X Up to date 0 N/A Remarks: All relevant OU I. OU2. and OU3 reports are stored in Administrative Record files at repositories established for the Site. Leachate Extraction Records 0 Readily available 0 Up to date X NIA Remarks Discharge Compliance Records 0 Air 0 Readily available 0 Up to date XN/A 0 Water (effluent) 0 Readily available X Up to date 0 N/A Remarks Daily Access/Security Logs X Readily available X Up to date 0 N/A Remarks I. 2. 3. A. I. B. I. • IV. O&M COSTS O&M Organization 0 State in-house 0 Contractor for State 0 PRP in-house X Contractor for PRP 0 Federal Facility in-house0 Contractor for Federal Facility 0 Other O&M Cost Records -detailed records not available 0 Readily available 0 Up to date D Funding mechanism/agreement in place • Five-Year Review FCX-Statesville Statesville, Iredell County, NC Original O&M cost estimate 0 Breakdovm attached Total annual cost by year for review period if available From To 0 Breakdovm attached Date Date Total cost From To 0 Breakdown attached Date Date Total cost From To 0 Breakdown attached Date Date Total cost From To 0 Breakdown attached Date Date Total cost From To 0 Breakdown attached Date Date Total cost Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: NIA - V. ACCESS AND INSTITUTIONAL CONTROLS 0 Applicable 0 NIA Fencing Fencing damaged X Location shown on site map X Gates secured 0 NIA Remarks Othef Access Restrictions Signs and other security measures 0 Location shown on site map 0 NIA Remarks:EPA and "No Trespassing" Signs have been removed many times through the years. C. I. 2. D, I. 2. 3. A. I. • Institutional Controls (ICs) Implementation and enforcement Site conditions imply !Cs properly implemented Site conditions imply !Cs not being fully enforced • Five-Year Review FCX-Statesville Statesville, Iredell County, NC X Yes 0 No 0 NIA 0 Yes 0 No 0 NIA Type of monitoring (e.g., self-reponing, drive by) __ Drive by and selfreponing Frequency Twice a vear Responsible panylagency _PRP Contact Ken Oma Project Manager 11 AQr 2006 (615) 250-1235 Name Title Date Phone no. Reporting is up-to-date X Yes 0 No 0 NIA Repons are verified by the lead agency X Yes 0 No 0 NIA Specific requirements in deed-or decision documents have been ~et X Yes 0 No 0 NIA Violations have been reported 0 Yes 0 No 0 NIA Other problems·or suggestions: 0 Repon attached IC not in Qlace for OUI. IC Qartly in Qiace for OU3. PRP's are working on finishing IC's for QTOQertv recently QUrchased Adequacy D !Cs are adequate X !Cs for OU I are inadequate 0 NIA Remarks: !Cs not in Qlace for OU!. !Cs in Qlace for OU3 General Vandalism/trespassing D Location shown on site map D No vandalism evident Remarks Minor Vandalism Land use changes on site X NIA Remarks: None at present. but land use changes may take place if sale of former FCX property or former Burlington propeny takes place in the future. Land use changes off site X NIA Remarks ~ ' VI. GENERAL SITE CONDITIONS Roads X Applicable 0 NIA Roads damaged X Location shown on site map X Roads adequate 0 NIA Remarks • • Five-Year Review FCX-Statesville Statesville, Iredell County, NC B. Other Site Conditions VII. LANDFILL COVERS 0 Applicable XN/A A. Landfill Surface I. Settlement (Low spots) 0 Location shown on site map 0 Settlement not evident Areal extent Depth Remarks ' 2. Cracks 0 Location sho~'Il on site map 0 Cracking not evident Lengths Widths Depths Remarks 3. Erosion 0 Location shown on site map 0 Erosion not evident Areal extent Depth Remarks 4. Holes 0 Location shown on site map 0 Holes not evident Areal extent Depth Remarks 5. Vegetati\.'e Co\'er 0 Grass 0 Cover properly established 0 Trees/Shrubs ( indicate size and locations on a diagram) D No signs of stress Remarks 6. Alternative Co\'er (armored rock. concret_e. etc.) 0 NIA Remarks 7. Bulges 0 Location shown on site map 0 Bulges not evident Areal extent Height Remarks 8. Wet Areas/Water Damage 0 Wet areas/water damage not evi_dent 0 Wet areas 0 Location shown on site map Areal extent 0 Ponding 0 Location shown on site map Areal extent 0 Seeps 0 Location sho\\11 on site map Areal extent 0 Soft subgrade D Location shown on site map Areal extent Remarks 9. Slope Instability 0 Slides 0 Location shown on site map D No evidence of slope instability Areal extent Remarks • • Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC B. Benches 0 Applicable X NIA I. Flows Bypass Bench Remarks 0 Location shown on site map D NIA or okay 2. Bench Breached Remarks 0 Location shown on site map D NIA or okay 3. Bench Overtopped 0 Location sho\\TI on site map D NIA or okay Remarks C. Letdown Channels D Applicable XNIA I. Settlement D Location shown on site map D No evidence of settlement Areal extent Depth Remarks 2. Material Degradation D Location shown on site ma'p D No evidence of degradation Material type Areal extent Remarks ' 3. Erosion 0 Location shown on site map 0 No evidence of erosion Areal extent Depth Remarks 4. 5. 6. D. I. 2. 3. 4. 5. • • Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC Undercutting 0 Location shown on site map D No evidence of undercutting Areal extent Depth Remarks Obstructions Type D No obstructions 0 Location shown on site map Areal extent Size Remarks Excessive Vegetative Growth Type . D No evidence of excessive grO\vth 0 Vegetation in channels does not obstruct flow 0 Location shown on site map Areal extent Remarks - Cover Penetrations 0 Applicable 0 NIA Gas Vents 0 Active D Passive D Properly secured/locked D Functioning D Routinely sampled D Good condition 0 Evidence of leakage at penetration · 0 Needs Maintenance 0 NIA Remarks Gas Monitoring Probes D Properly secured/Jocked O Functioning 0 Routinely sampled D Good condition D Evidence of leakage at penetration 0 Needs Maintenance 0 NIA Remarks Monitoring Wells (within surface area of landfill) D Properly secured/locked O Functioning 0 Routinely sampled D Good condition D Evidence of leakage at penetration D Needs Maintenance 0 NIA Remarks Leachate Extraction Wells 0 Properly secured/locked D Functioning 0 Routinely sampled D Good condition 0 Evidence of leakage at penetration 0 Needs Maintenance 0 NIA Remarks Settlement Monuments D Located 0 Routinely surveyed 0 NIA Remarks E. I. 2. 3. F. I. 2. G. I. 2. 3. 4. • Gas Collection and Treatment 0 Applicable 0 NIA Gas Treatment Facilities 0 Flaring 0 Thermal destruction D Collection for reuse 0 Good condition O Needs Maintenance Remarks Gas Collection Wells, Manifolds and Piping D Good condition O Needs Maintenance Remarks • Five-Year Review FCX-Statesville Statesville, Iredell County, NC Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or building~) D Good condition O Needs Maintenance 0 NIA Remarks Co\'er Drainage Layer 0 Applicable 0 NIA Outlet Pipes Inspected 0 Functioning 0 NIA Remarks Outlet Rock Inspected 0 Functioning 0 NIA Remarks Detention/Sedimentation Ponds D Applicable 0 NIA Siltation Areal extent Depth 0 NIA D Siltation not evident Remarks Erosion Areal extent Depth D Erosion not evident Remarks . Outlet Works D Functioning 0 NIA Remarks - Dam 0 Functioning 0 NIA Remarks H. I. 2. I. I. 2. 3. 4. I. 2. • Retaining Walls 0 Applicable 0 NIA Deformations D Location shO\vn on site map • Five-Year Review FCX-Statesville Statesville, Iredell County, NC D Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks , Degradation D Location shown on site map D Degradation not evident Remarks Perimeter Ditches/Off-Site Discharge 0 Applicable 0 NIA Siltation D Location shown on site map D Siltation not evident Areal extent Depth Remarks Vegetative Growth D Location sho\\TI on site map 0 NIA 0 Vegetation does not impede flow Areal extent Type Remarks Erosion D Location shown on site map 0 Erosion not evident Areal extent Depth Remarks Discharge Structure D Functioning 0 NIA Remarks VIII. VERTICAL BARRIER WALLS 0 Applicable X N/A Settlement D Location shown on site map D Settlement not evident Areal extent Depth Remarks Perform3nce Monitoring Type of monitoring D Performance not monitored Frequency D _Evidence of breaching Head differential Remarks A. I. 2. 3. B. I. 2. 3. • • Five-Year Review FCX-Statesvifle Statesville, Iredell County, NC IX. GROUNDWATER/SURFACE WATER REMEDIES X Applicable □ NIA Groundwater. Extraction Wells. Pumps, and Pipelines X Applicable 0 NIA Pumps, Wellhead Plumbing, and Electrical 0 Good condition 0 All required wells properly operating 0 Needs Maintenance 0 NIA Remarks: All inspected wells are in good condition Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances 0 Good condition 0 Needs Maintenance Remarks: GW remediation system equipment has functioned properly. Spare Parts and Equipment 0 Readily available 0 Good condition O Requires upgrade 0 Needs to be provided Remarks Surface Water Collection Structures, Pumps. and Pipelines 0 Applicable X NIA Collection Structures, Pumps, and Electrical D Good condition O Needs Maintenance Remarks Surface Water Collection System Pipelines, Valves. Valve Boxes, and Other Appurtenances 0 Good condition O Needs Maintenance Remarks Spare Parts an.d Equipment 0 Readily available 0 Good condition O Requires upgrade 0 Needs to be provided Remarks C. I. 2. 3. 4. 5. 6. • Treatment System X Applicable 0 NIA Treatment Train (Check components that apply) 0 Metals removal 0 Oil/water separation X Bioremediation 0 Air stripping 0 Carbon adsorbers 0 Filters 0 Additive (e.g .. chelation agent, flocculent) 0 Others Air SQarging!'.Soil Vent Extraction X Good condition 0 Needs Maintenance X Sampling ports properly marked and functional X Sampling/maintenance log displayed and up to date 0 Equipment properly identified 0 Quantity of groundwater treated annually 0 Quantity of surface water treated annually Remarks: Electrical Enclosures and Panels 0 NIA X Good condition 0 Needs Maintenance Remarks: properly rated and functional Tanks, Vaults, Storage Vessels Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC 0 NIA X Good condition D Proper secondary containment 0 Needs Maintenance Remarks Discharge Structure and Appurtenances 0 NIA X Good condition 0 Needs Maintenance Remarks Treatment Building(s) 0 NIA X Good condition (esp. roof and doorways) 0 Chemicals and equipment properly stored 0 Needs repair Remarks Monitoring Wells (pump and treatment remedy) 0 Properly secured/locked X Functioning X Routinely sampled 0 Good condition D All required wells located 0 Needs Maintenance 0 NIA Remarks: 50-60 wells locted on-Site and used during OU I and OUJ remedies D. Monitoring Data I. Monitoring Data Is routinely submined on time X ls of acceptable quality 2. Monitoring data suggest~: D Groundwater plume is effectively contained X Contaminant concentrations a_re declining D. I. A. B. • • Five-Year Review FCX-Statesville Statesville, Iredell County, NC l\tlonitored Natural Attenuation Monitoring Wells (natural attenuation remedy) D Properly secured/locked X Functioning X Routinely sampled X Good condition D All required wells located D Needs Maintenance 0 NIA Remarks X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, anach an in~pection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e .. to contain contaminant plume. minimize infiltration and gas emission. etc.). OU 1 GW system is currently off line. A ROD Amendment was issued in Se12tember 2006 to change the remedy to monitored naturai attenuation. ' ' . OU3 GW system is working 12ro12erly. Accelerated monitored attenuation will be used in the future to s11eed UQ the OU3 remedy. Institutional controls need to be im11lemented for OU 1. !C's are in Qlace for OU3. Adequa9· of O&M Describe issues and observations related to the implementation and scope of O&M Procedures. In particular. discuss their relationship to the curre.nt and long-term protectiveness of the remedy. O&M is adeguate C. D. • Early Indicators of Potential Remedy Problems Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, which suggest that the protectiveness of the remedy may be compromised in the future. NIA - Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. The OU\ remedy change from groundwater pump-and-treat to MNA was one of several recommendations made during an Optimization Evaluation performed at the Site in 2000. ' • ATTACHMENT 3 Community Notice Five-Year Review FCX-Statesville Statesville, Iredell County, NC EPA provided adequate notice of the Five-Year Review process during the public meeting held for the OU1 ROD Amendment and OU3 ESD on April 11, 2006. Following signature of the Five-Year Review, EPA will publish an announcement in the Statesville newspaper that the first Five-Year Review process for the Site has been completed. • ATTACHMENT 4 Complete Interviews • Five-Year Review FCX-Statesvil/e Statesville, Iredell County, NC • FCX-Statesville Site Statesville, Iredell County, NC EPA ID: NCD 095458527 Superfund Five Year Review Report • Five-Year Review FCX-Statesville Statesville, Iredell County, NC EPA conducted Site interviews during the public meeting for the OU1 ROD Amendment held on April 11, 2006. EPA discussed Site activities with the public, including the OU1 ROD Amendment, the OU3 ESD, and the.Five-Year Review process. All questions and comments received during the meeting were answered. Interview Questionnaire Completed by Ken Mallary, US EPA RPM 1. What is your overall impression of the project? (general sentiment) Since 1998, the OU1. OU2, and OU3 Remedial Actions have not only reduced the amount of source contamination at the Site, and levels of Site-related contaminants in groundwater, but reduced the potential risks to the human population living around the Site. 2. What effects have site operations had on the surrounding community? I am not aware of any adverse effects that Site operations have had in the surrounding community. A local community group was awarded a Technical Assistance Grant (TAG) in 1993. Working with their technical advisor, the local community remained involved in the decision- making process at the Site for the next 5 or 6 years. Despite the fact that the local community group's interest level has diminished since 2001, several nearby residents have_ continued to show an interest in the Site. 3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. The local community group, working with their technical advisor, documented _several concerns to EPA during the selection of the OU1 and OU2 remedies (for specific concerns, refer to the responsiveness suminary for the OU1 ROD and OU2 ROD. As required, EPA took the community concerns into consideration before making the final selection of the OU1, OU2, and OU3 remedies. 4. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the responses. No. 5. Do you feel well informed about the site's activities and progress? Yes. 6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? No. 7. What is the current status of construction (e.g., budget and schedule)?. • Five• Year Review FCX-Statesville Statesville, Iredell County, NC Construction Completion was achieved at the Site in 2001, meaning the OU1, OU2, and OU3 remedies were constructed and operational/functional. EPA is now in the process of finalizing a ROD Amendment for OU1, which will change the OU1 remedy from groundwater pump-and-treat to Monitored Natural Attenuation (MNA). EPA is also in the process of enhancing the OU3 remedy by adding Accelerated Natural Attenuation (ANA) to the existing OU3 remedy. 8. Have any problems been encountered which required, or will require, changes to this remedial design or this ROD? See answer to question #7 above. 9. Have any problems or difficulties been encountered which have impacted construction progress or implementability? Several.issues have been encountered at the Site since EPA became involved. Following the signing of the OU1 ROD, a delay in funding caused the construction of the pump-and-treat system to be postponed for several years. Numerous technical issues were also encountered during the OU2 Remedial Action, which resulted i_n delays in the soil treatment process. 10. Do you have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, constructability, management, regulatory agencies, etc.)? Do you have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, constructability, management, regulatory agencies, etc.)? I have no suggestions or recommendations at this time. 11. Is the remedy(ies) functioning as expected? How well is the remedy performing? See responses to questions #1 and #7 above. 12. What does the monitoring data show? Are there any trends that show contaminant le".els are decreasing? Yes -decreases in pesticide concentrations in groundwater documented since 2000 have brought about the OU1 remedy change. The OU2 Remedial Action successfully addressed the pesticide soil contamination on the former FCX property. Data collected during the OU3 Remedial Action indicates the VOC source area is being effectively reduced. EPA expects the remedial action objectives for the OU1 and OU3 remedies will be accomplished in a reasonable timeframe. · 13. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there . is not a continuous on-site presence, describe staff and frequency of site. inspections and activities. A continuous on-site presence is not required during the O&M activities at the Site. However, groundwater monitoring is required on a regular basis as part of the OU1 and OU3 remedies.