NCD122263825_19990505_JFD Electronics - Channel Master_FRBCERCLA ROD_Record of Decision 1992 - 1999-OCR

NORTH ~rtOLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Mr. McKenzie Mallary
Remedial Project Manager
May 5, 1999
Superfund Branch, Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 3 03 03
DIVISION OF WASTE MANAGEMENT
RE: State Concurrence with the Amendment to the 1992 Record of Decision
JFD/Channel Master NPL Site
Oxford, Granville County, NC
Dear Mr. Mallary:
The State of North Carolina has reviewed the Amendment to the 1992 Record of
Decision for the JFD/Channel Master National Priority List (NPL) Site. The State
ofNorth Carolina concurs with the remedy changes, subject to the following
conditions.
I. State concurrence on the Amendment-to the 1992 Record of
Decision (ROD) and the selected remedy for the site is based solely
on the information contained in the subject Amendment to the
ROD. Should the State receive new or additional information that
significantly affects the conclusions or remedy selection contained
in the ROD or this Amendment to the ROD, it may modify or
withdraw this concurrence with written notice to the United States
Environmental Protection Agency (US EPA) Region IV.
2. State concurrence on this Amendment to the 1992 ROD in no way
binds the State to concur in future decisions or commits the State
to participate, financially or otherwise, in the·clean up of the site.
The State reserves the right to review, overview, comment, and
make independent assessment of all future work relating to this site.
401 OBERLIN ROAD, SUITE 1 SO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER P.t.PER
• • Mr. McKenzie Mallary
May 5, 1999
Page 2
3. If, after remediation is complete, the total residual risk level exceeds 10·6, the State
may require deed recordation/restriction to document the presence of residual
contamination and possibly limit future use of the property as specified in NCGS
130A-310.8.
The State of North Carolina appreciates the opportunity to comment on the Amendment to the
1992 Record of Decision for the subject site, and we look forward to work1ng with the US EPA
on the final remedy. If you have any questions or comments, please feel free to contact me at
[phone], extension 291.
Attachment
;z;h::,d,/~
Remediation Branch Head
Superfund Section
cc Phil Vorsatz, NC Remedial Section Chief
Jack Butler, Chief NC Superfund Section
David Mattison, NC Superfund Section
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AMENDMENT TO THE
1992 RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
JFD ELECTRONICS/CHANNEL MASTER SITE
OXFORD, GRANVILLE COUNTY, NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GA
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Record ol OeciBiQIJ AmenQrnent
Jr-:D l'::!eclronics/Channal Maa1er S11e
DECLARATION FOR THE
RECORD OF DECISION AMENDMENT
Fundamental Change to the Selected Sludge and Soil Remedy
In the 1992 Record of Decision
SITE NAME AND LOCATION
JFD Electronics/Channel Master Site
Oxford, Granville County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This amendment to the 1992 Record of Decision .(ROD) document presents a
fundamental change to the selected remedial action forthe contaminated sludge/soil at the
JFD Electronics/Channel Master Site located in Oxford, Nortl1 Carolina, chosen in
accordance with CERCLA, as amended by SARA and, to the extent practicable, the
National Contingency Plan. This decision is based on the Administrative Record for this
Site.
The State of North Carolina concurs with the amended remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD Amendment, may
continue to present an imminent and substantial endangerment to,public health, welfare,
or the environment.
DESCRIPTION OF THE MODIFIED REMEDY
The purpose of this ROD Amendment is to announce a modification-of the remedy
for the contaminated sludge and soil, based upon new information including results from
the 1994 and 1995 Treatability Studies and sampling data collected during the Remedial
Design. The amended remedy is more effective for the particular conditions posed by this
Site.
The major components of the modified remedy include:
excavating approximately 1,750 cubic yards of ,cyanide-impacted sludge;
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Rooord of DEJcl&ion Amendmerit
JFD E.\Qc::1tor1\ci;/Cham1t1I Mas1ar ~i1e
transporting the sludge off-site to an appropriate treatment and disposal
focility;
treating the sludge with alkaline chlorination to reduce levels of cyanide;
reducing any hexavalent chromium present in the s!udge to trivalent
chromium;
stabilizing the sludge for metals to reach the disposal requirements
established by the disposal facility; and
disposing of the treated and stabilized sludge in the off-site facility.
The contaminated soil which does not require treatment for cyanide, but does
require treatment for metals, would remain on-site for treatment and disposal. The
selected remedy for the contaminated soil would include:
stabili~ing the contaminated soil by adding Portland Cement;
sampling and analyzing the cured mixture to confirm that it meets the
treatment levels established in the 1992 ROD for each metal, as well as the
compressive strength requirements of 20 pounds per square incl1 (psi); and
covering the treated material with topsoil and seeding the areas with a
vegetative cover.
STATUTORY DETERMINATIONS
The modified remedy is protective of human health and lhe environment, complies
with Federal and Stale requirements that are legally applicable or relevant and appropriate
to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable for t11is Site, and
satisfies the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Richard D. Green, Date
Director, Waste Management Division
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Record ol Oecl&lon Am1ndmpn!
JFD ElociroolCOX:hMnol M .. ,., $I\o
SECTION
TABLE OF CONTENTS
DECISION SUMMARY
1.0 INTRODUCTION
TABLE OF CONTENTS
1.1 Site Name and Location
1.2 Public Participation
1.3 1992 Record of Decision
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1.4 Summary of the Circumstances Leading to the
ROD Amendment
1.5 Administrative Record
1.6 Ad.mlnlstratlve Record Availability
Aprll 1899
PAGE NUMBER
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2.0 REASONS FOR ISSUING THE ROD AMENDMENT 4
2.1 Description of the Sludge end Soll Remedy Selected
In the 1992 ROD 4
2.2 Rationale For Amending the Remedy
In the 1992 ROD 4
2.2.1 Results of the Treatablllty Study 6
2.2.2 Evaluation of the Supplemental Feasibility Study 7
3.0 · OTHER ALTERNATIVES CONSIDERED IN THE 1992
ROD FOR THE SLUDGE AND SOIL
4.0 COMPARISON OF THE SLUDGE AND SOIL REMEDY
IN THE 1992 ROD WITH THE MODIFIED REMEDY
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Rgoord o! Dacir.ion Arnandmen1
JrD Eloc1ronlc.MChBnnAI Mi:t:s.icr Sile
TABLE OF CONTENTS
SECTION
5.0 EVALUATION OF THE MODIFIED REMEDY
5.1 Overall Protection of Human Health
and the Environment
5.2 Compliance with ARARs
5.3 Long-term Effectiveness and Permanence
5.4 Reduction of To><lclty, Mobility, or Volume
5.5 Short-term Effectiveness
5.6 Implementability
5.7 Cost
5.8 State Acceptance
5.9 Community Acceptance
6.0 STATUTORY DETERMINATIONS
7.0 RESPONSIVENESS SUMMARY
APPENDIX A -ORIGINAL RECORD OF DECISION
FIGURE 1 -SITE LOCATION MAP
FIGURE 2 -AREAS OF SLUDGE AND SOIL
REQUIRING REMEDIATION
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April 18'::/9
PAGE NUMBER
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Racord o1 Der.lslon AmDndmen1
JFD Elec1ronlcs./Chann81 Mru.1er Siie /I ril 1 'J99
DECISION SUMMARY
1.0 INTRODUCTION
1.1 SITE NAME AND LOCATION
The 13.09-acre JFD Electronics/Channel Master Site (the "Site") is located
approximately 2 miles southwest of Oxford, Granville County, North Carolina, at the
intersection of Pine Tree Road and Industry Drive. The Site is bordered Oil tl1e east•by a
residential development, and to the south by a railroad spur owned and operated •by
Southern Railroad. Figure 1 shows the location of the Site. The main building at the•Site
is currently utilized by Hamilton/Avnet Corporation as a distribution warehouse, and a
smaller warehouse on the eastern portion of .the property is owned and operated by the
Bandag Corporation.
The Site was operated by JFD Electronics as a manufacturer of television antennas
from 1961 to 1979. The manufacturing processes involved a copper/nickel electroplating
and chrome conversion coating of antenna parts. Wastes generated from the processes,
primarilywastewaters and sludge, contained a number of metals including cliromium, lead,
and cyanide. Wastewater from the electroplating and chrome conversion processes were
treated in an on-site treatment plant consisting of interconnecting concrete tanks.
Treatment included the reduction of hexavalent chromium to trivalent chromium. Sludge
generated from the treatment process was disposed in sludge drying beds along the
southern property boundary, and also accumulated in an unlined lagoon.
Channel Master owned the property from 1980 to 1984, during which ti me they
produced satellite antennae, amplifiers, and boosters at the Site. The. North Carolina
Department of Human Resources (now called the North Carolina Department of
Environment and Natural Resources -NCDENR) conducted a Site lnspec!.ion at the Site
in 1987 Channel Master conducted a voluntary cleanup of t110 lagoon in 1987 and 1988,
under the •direction and supervision of the North Carolina Department of Human
Resources. The Site was subsequently proposed for inclusion on the National Priorities
List in June 1988 and finalized In October 1989.
EPA initiated a Remedial Investigation/Feasibility Study (RI/FS) at the Site in 1991.
The Record of Decision (ROD) was signed in September 1992. Negotiations for
settlement regarding implementation of the Remedial Design/Remedial Action (RD/RA)
began in October 1992, and a Consent Decree was signed in 1993
1
Record~ Deci:s.iori Amendmen1
JFO EJecl:i ca.ics/Chan'lel Ma6i8t Site
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FIGURE 1
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necord of Dttcislon Am11ndmen1 April 19~9
1.2 PUBLIC PARTICIPATION
The public participation requirements of both CERCLA Section 117 and Section
300.435(c)(2)(ii) of the NCP have been satisfied. A press release was issued <1nd f<1ct
sheets were sent to persons on EPA's Site mailing list. A newspaper advertisement
describing the proposed amendment and announcing the public comment period was
placed in the Oxford Ledgeron April 13, 1998, and in the Henderson Dispatch on April 14,
1998. A thirty-day public -comment period was provided, and EPA has addressed all
comments in the attached Responsiveness Summary.
1.3 1992 RECORD OF DECISION
The original ROD was signed by the Regional Administrator on September 12,
1992. The State of North Carolina concurred with the selected remedy.
1.4 SUMMARY OF THE CIRCUMSTANCES LEADING TO THE ROD
AMENDMENT
Alkaline chlorination was selected as the type of oxidation/reduction treatment
technology for addressing tl1e contaminated sludge and soil at the Site. Treatability
Studies were conducted in 1994 and 1995 to demonstrate that alkaline chlorination could
reduce levels of cyanide in the contaminated sludge and soil to meet the remediation
levels in the 1992 ROD, and to evaluate if alkaline chlorination could be.extrapolated to
full-scale application.
1.5 ADMINISTRATIVE RECORD
The requirements set forth in Section 300.825(a)(2) of the NCP ~ave been satisfied.
All documents that form the basis for the decision to amend the sludge and soil remedy
have been added to the Administrative Record.
1.6 ADMINISTRATIVE RECORD AVAILABILITY
The Administrative Record is available for viewing by the public during regular
business hours at the following locations:
Richard H. Thornton Public Library
Corner of Main and Spring Streets
Oxford, North Carolina
[phone]
USEPA Region IV Records Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
( 404) 562-8946
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Rur.ord of Docislon Ar118ndmgn1 t,.prll 1999 JFD El6Clronlcs/Channol Masl{H Slle
Copies of documents in the Administrative Record may also be obtained from EPA's
Region IV Records Center in Atlanta by writing to the Freedom-of-Information Act (FOIA)
Coordinator and requesting a copy of the JFD Electronics/Channel Master Administrative
Record Index. Choices of documents from the Index maybe expressed in additional FOIA
requests.
2.0 REASONS FOR ISSUING THE ROD AMENDMENT
2.1 DESCRIPTION OF THE SLUDGE AND SOIL REMEDY SELECTED IN THE
1992 ROD
Page 98 of the 1992 ROD, Section X.B. -Sludge/Soil Remediation, addresses
approximately 3,000 cubic yards of sludge and soil contamination at the Site. Alternative
#4 includes the excavation of the sludge and soil, on-site tr-eatment with alkaline
chlorination, stabilization, backfilling on-site, and capping. Figure 2 shows the areas of
sludge and soil requiring remediation. One objective of the remedy included pr.eventing
direct,contact with and/or ingestion of the contaminated sludge and soil contai11ing metals
above health-based levels. Another objective of the remedy included preventing the
release of the sludge and soil contamination via surface water runoff from the Site,
thereby preventing surface water and sediment contamination in nearby drainage ditcl1es
and streams. Another objective of the remedy was to eliminate the sludge and soil as a
potential source of groundwater contamination.
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2.2
The ROD required the following remediation levels for metals in the sludge and soil:
Levels in the sludge and soil must be reduced to 590 milligrams per liter (mg/I) of
total cyanide in the 11on·TCLP extract and 30 mg/I of amenable cya11ide; and
Metals levels in the TCLP extract must not exceed the Land Disposal Restrictions
(LDRs) levels provided below;
Cadmium 0.066 mg/I
Chromium 5.2 mg/I
Lead 0.51 mg/I
Nickel 0.32 mg/I
Silver 0 072 mg/I
RATIONALE FOR AMENDING THE REMEDY IN THE 1992 ROD
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AREAS OF SLUDGE AND SOIL REQUIRING REMEDIATION
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Rocotd o! D0ciaion Amendment April \998 JFD Eltm1roriir.s16hannf!! Maslor Silo
2.2.1 Results of the Treatablllly Study
As required in the 1992 ROD, a treatability study was conducted in 1994 to evaluate
the effectiveness of alkaline chlorination in reducing the levels of cyanide in the sludge
and soil. The results of this initial treatability study indicated that cyanide oxidation and
reduction by alkaline chlorination under the conditions tested was not sufficien\.to meet the
remediation levels in the 1992 ROD. Total cyanide concentrations ranged from 4,600
milligrams per kilogram (mg/kg) to 5,500 mg/kg before treatment. Following treatment, the
levels of cyanide ranged from 1,400 mg/kg to 1,900 mg/kg, well above the remediation
level of 590 mg/kg total cyanide established in the 1992 HOD. Based on a review of the
treatability study data, EPA concluded, "It Is likely that the cyanide cannot be completely
oxidized because of the formation of iron and nickel -complexes"
After reviewing the Treatability Study in 1994, EPA recommended that additional
treatability testing be conducted to evaluate alternative treatment technologies. Additional
testing of alkaline chlorination was performed during the summer of 1994. The -results
from this additional study indicated the remediation levels required in the 1992 ROD for
cyanide were achieved using alkaline chlorination; however, due to the apparent oxidation
of chromium during the alkaline chlorination process, the levels of•chr-omium in the sludge
did not meet the remediation levels in the 1992 ROD.
In 1995, after evaluating and screening a number of potential technologies,
Geraghty & Miller recommended conducting further testing of the sludge using hot alkaline
chlorination and low temperature thermal desorption. The results of the 1995 study
indicated that both hot alkaline chlorination and low temperature thermal desorption could
be used to successfully remediate cyanide to reach the remediation levels required in the
1992 ROD. However, both treatment processes exhibit technological limitations which
may require additional treatability or pilot scale testing. These limitations may inhibit full
scale implementation of the technology. The two technologies were summarized as
follows:
•
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Hot alkaline chlorination required a high chemical dose and a moderately long
treatment time, and produces a significant amount of hexavalent chromium during
the cyanide oxidation process. Treatment of cyanide by hot alkaline chlorination
would require cyanide oxidation at an elevated pH, reduction of chromium at a low
pH, and subsequent neutralization and soil stabilization.
Treatment of cyanide by low temperature thermal desorption also removed cyanide
to the remediation levels; however, some oxidation of chromium occurred.
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Rocor'd o! lJ0ci&1on Amendmcnl /\()(fl 1 iJ99 JFD f:leC1ronlC1:/Che.nnel MRSlcr SllCJ
2.2.2 Evaluation of the Supplemental Feaslbility Study
Based on the treatability studies conducted in 1994 and 1995, Geraghty & Miller conducted a Supplemental Feasibility Study (SFS) in 1996. The objectives of the SFS were as follows:
• supplement the initial Feasibility Study with a review and assessment of
alkaline chlorination and thermal desorption, as well as alternate treatment
technologies for cyanide and metals in the sludge and s011;
develop detailed cost estimates for the hot alkaline-chlorination and thermal desorption technologies retained in this assessment; and
recommend a specific treatment technology which can achieve the
remediation levels required in the 1992 ROD for cyanide and metals.
3.0 OTHER ALTERNATIVES CONSIDERED IN THE 1992 ROD FOR THE SLUDGE
AND SOIL
The 1992 Feasibility Study evaluated five r-emedial alternatives for addr-essing the contaminated sludge and soil at the ·site. The following paragraph provides a brief evaluation of the four alternatives not selected in the 1992 ROD.
The first alternative included a "No Action" alternative. The 1992 Feasibility
Study determ·ined that the "No Action" alternative would not be protective of human
health and the environment. Therefore, the "No Action" alternative was not acceptable to EPA.
The second alternative involved the use .of fencing, warning signs, deed restrictions, and capping as a means of providing protection to human health and the environment Using institutional actions and capping the Site would reduce the mobility of the sludge and soil, but would not reduce the toxicity or volume of the sludge and soil. Leaving the sludge and soil on the Site would require Implementing deed restrictions for future land use and maintaining the warning signs and fencing. The long-term effectiveness of this alternative is questionable.
The third alternative would involve excavating and transporting the sludge and soil off-site for treatment and disposal. While this remedy would effectively remove the sludge and soil from the Site, the storage, transportation and disposal of the
contaminated sludge and soil would be subject to RCRA and DOT regulations.
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AGoord 01 Oeci&ioo Amandmen1 Anril 1~98 JFD E11tc1ronlc\./Chflflncl M1D11or·s11a
The fifth alternative involved excavation and on-site treatment with vitrification and subsequent backfilling and capping. This alternative would be a permanent
remedy that would reduce the risks associated with the sludge and soil at the Site. However, vitrification is a new innovative technology, and there is limited-data
available to evaluate this technology's effectiveness.
4.0 COMPARISON OF THE SLUDGE AND SOIL REMEDY IN THE 1992 ROD
WITH THE MODIFIED REMEDY
The original remedy in the 1992 ROD required approximately 3,000 cubic yards
of-contaminated sludge and soil to be excavated from the eleven sludge drying-beds
and surrounding areas. Figure 2 shows the areas identified in the 1992 ROD requiring
remediation. Verification sampling would be performed during the excavation to ensure that the areas identified with sludge contamination have been excavated The 1992
ROD required the sludge and soil be stockpiled, slurried, and transferred to a tr.eatment
vessel where the alkaline chlorination process would take place. A cleanup
verification plan would be prepared during the design phase to ensure that tl1e
appropriate number of samples are collected to prove that the Site has been
remediated.
Cyanide and TCLP analysis would be performed during the treatment process to
ensure that the alkaline chlorination treatment process is achieving the remediation
levels established in the 1992 ROD. Following the alkaline chlorination process, the sludge and soil would be stabilized with a chemical reagent such as Portland Cement. The treated sludge and soil would then be backfiiled into the excavated a~eas and
capped. For detailed descriptions of Alternative #4, refer to Section 6.5.2 of the 1992
Feasibility Study, as well as Section VIII B. page 82, and Section X, page 98, of the
1992 ROD.
The modified remedy requires treatment of 3,000 cubic yards of contaminated
sludge and soil, including 1,750 cubic yards or cyanide-impacted sludge requiring
cyanide treatment and subsequent metals stabilization, and 1,250 cubic yards of soil
requiring metals stabilization. The 1,750 cubic yards of contaminated sludge would-be excavated and transported to an approved off-site facility for treatment and disposal.
The 1,250 cubic yards of contaminated soil would be stabilized on-site, backfilled into
the excavated areas, covered with soil, and seeded with vegetative cover. The
remediation levels for the soil in the modified remedy are the same as the remediation levels in the 1992 Record of Decision.
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Record of Dcdslon Amandm11n1
Ele<o1ronicslCh6flnGI M.u;:!er Si1a
5.0 EVALUATION OF THE AMENDED REMEDY
5.1 Overall Protection of Human Health and the Environment
The remedy in the 1992 ROD provided a permanent treatment thereby eliminating the potential risks associated with the dermal contact and ingestion of the sludge and soil. The remedy would also eliminate the.potential for the contaminants in the sludge and soil from migrating off-site via surface water runoff and adversely impacting the nearby drainage ditches and streams.
Similar to the original remedy, the modified remedy would provide a permanent treatment thereby eliminating the potential dermal contact and ingestion of the sludge and soil. The modified remedy would also eliminate the potential for contaminants in the soil from migrating ofr-site via surface water runoff and adversely impacting the nearby drainage ditches and streams, For additional information regarding the amended remedy, please refer to the Supplemental Feasibility Study located in the · Administrative Record files (see Section 1.6 for the locations).
5.2 Compliance with ARARs
The ARARs governing the Implementation of Alternative #4, as described in the 1992 Feasibility Study, would apply to the excavation, treatment, and disposal of the sludge and soil, reclamation and capping of the excavated areas, and the monitoring
activities. The Land Disposal Restrictions (LDRs) {40 CFR Part 268] are not an ARAR for the on-site treatment of the soil as long as the excavated RCRA wastes are not removed from the areas of concern during the remedial action All appropriate North Carolina Solid Waste Disposal Regulations .[NCAC, Title 15A, Ch. 138] identified in the 1992 ROD would be an ARAR for this remedy.
Excavating and transporting the sludge off-site for treatment and disposal would trigger Department of Transportation regulations for the transportation of RCRA hazardous waste (49 CFR Parts 107, 171-179], and RCRA Land Disposal Restrictions (LDRs) because the sludge is characterized as FOOS and F019 RCRA_ hazardous waste (40 CFR Part 268]. The off-site treatment and disposal facility would be responsible for the appropriate RCRA permits as a Treatment, Storage, and Disposal facility [40 CFR Part 262]. The Occupational Safety and Health Regulations (OSHA}, and the North Carolina Solid Waste Disposal Regulations [NCAC, Title 15A, Cil. 13B], would be an ARAR for this remedy.
5.3 Long-term Effectiveness and Permanence
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Reoord o1 D8c!slon Ame11Cm~n1 Anrll 19t11:, JFD [loctronleb/OhMne] Masler Sito
Treatability Studies were conducted in 1994 and 1995 to evaluate the effectiveness .of the alkaline chlorination process in reducing the toxicity, mobility, and volume of contaminants in the sludge and soil. The results indicated that alkaline chlorination would not reduce the levels of cyanide in the sludge to meet the
remediation levels established in the 1992 ROD. Stabilization was not conducted on the sludge during the 1994 and 1995 Treatability Studies since the alkaline chlorination
treatment process was not successful.
The off-site treatment and disposal of the sludge would permanently and
effectively remove the sludge from the JFD -Electronics/Channel Master Site.
The contaminated soil would be stabilized-on-site to meet the remediation levels established in the 1992 ROD Sampling and analyzing the stabilized material for TCLP constituents would be requir-ed to verify the effectiveness of the remedy.
5.4 Reduction of Toxicity, Moblllty, or Volume
The 1994 and 1995 Treatability Studies indicated that the levels of cyanide in
the sludge were not reduced to the remediation levels established in the 1992 ROD. Therefore, the alkaline chlorination technology proved to be ineffective in reducing the toxicity of the sludge.
The volume of hazardous waste would be r.educed at the Site by excavating and transporting the sludge off-site to a treatment and-disposal facility. Stabilizing the contam·inated soil on-site would reduce its toxicity and mobility. However, the volume
of the soil would increase due to the addition of a chemical reagent such as Portland Cement.
5.5 Short-term Effectiveness
The 1994 and 1995 Treatabllity Studies indicated that an extremely large
volume of reagent would be needed to complete the alkaline chlori11at1011 process on-
site as part of the original 1992 remedy. The presence of large volumes of reagent on-site would present potential risks to workers and nearby residents The TreatabililY
Studies also indicated that the on-s·1te treatment process could 11wolve unnecessary risks due to the potential for cyanide gases being generated during the treatment
process.
By comparison, there is potential risk to the nearby community and remedial
workers due to the potent'1al for direct contact and inhalation of the contaminants in .the
sludge and soil during the implementation of the amended remedy. Potential risks to the community would also be of concern during transportation of the-sludge along
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Record ol Dar:lslon Amondment rll 1990 Jf:D le::lroni~/ChWlnOI Masler Sila
public roads and highways to the treatment and disposal facility. An implementation . plan and health and safety plan will be required as part of the Remedial Design in•order to minimize any potential impacts to nearby residents or to remedial workers performing the excavation, treatment, and disposal.
Confirmatory sampling and analysis of the excavated areas would be performed to ensure that all contamination has been excavated to meet the remediation levels specified in the 1992 ROD. Likewise, the stabilized soil will be analyzed to ensure that no leaching occurs above the remediation levels established in the 1992 ROD.
5.6 Implementability
The 1994 and 1995 Treatability Studies indicated that the use of alkaline
chlorination for treating the sludge and soil on-site would not be technically feasible. However, the on-site treatment of the contaminated soil using stabilization would ·be readily implementable.
The excavation and off-site treatment and disposal of the sludge would be readily implemented with no significant operational or administrative difficulties. Permitted treatment and disposal facilities are available with the necessary equipment and personnel to complGte the treatment process, Stabilization of contaminated soil is a proven technology; therefore, the on-site treatment of the contaminated soil would be readily implementable.
5.7 Cost
The 1992 ROD estimated the total present worth cost of the original sludge/soil remedy to be $1,211,000 However, based on the 1994 and 1995 Treatability Studies, the Supplemental Feasibility Study estimated the total present worth cost of the original sludge/soil remedy to be $5,048,577.
By comparison, the present worth total cost of the modified remedy, including excavating and transporting the sludge off-site for treatment and disposal, and stabilizing the soil on-site, is $2,582,385.
5.8 State Acceptance
The State of North Carolina Department of Environment, Hea!th, and Natural Resources (NCDEHNR), now called the NCDENR, concurred with the remedy selected in the 1992 ROD.
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Roe-Ord of Duci&ion Amitndmonl April 1999 JFO Elccironlcs/Channol Mas1ar Silo
The NCDENR concurs with this modified remedy.
5.9 Community Acceptance
The community generally accepted the original remedy in the 1992 ROD. See the Responsiveness Summary, which is APPENDIX B, to the 1992 ROD.
By comparison, the community generally accepts the amended remedy. The 30· day public comment period was held from April 14, 199B to May 13, 199B, and no written comments were received by EPA on the amended remedy.
6.0 STATUTORY DETERMINATIONS
The modified remedy-satisfies CERCLA Section 121; the remedy ls-protective of human health and the environment, complies with ARARs, is cost effective, and utilizes permanent solutions and alternative treatment technologies ·to the maximum extent practicable. Preference for treatment as a principal element is satisfied-by other aspects of the overall remediation of the JFD Electronics/Channel Master Site.
7.0 RESPONSIVENESS SUMMARY
EPA has addressed all comments In the attached Responsiveness Summary.
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Aeoord al Par::l~lon Amendrnen1 Aprll 1QQQ JFD t.leclron!cs/Chsn11RI Maslor bite
APPENDIX A
ORIGINAL RECORD OF DECISION
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AMENDMENT TO THE
1992 RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
JFD ELECTRONICS/CHANNEL MASTER SITE
OXFORD, GRANVILLE COUNTY, NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GA
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Record of Decision Amendment April 1999
JFD Electronics/Channel Master Site
DECLARATION FOR THE
RECORD OF DECISION AMENDMENT
Fundamental Change to the Selected Sludge and Soil Remedy
in the 1992 Record of Decision
SITE NAME AND LOCATION
JFD Electronics/Channel Master Site
Oxford, Granville County, North Caroli.na
STATEMENT OF BASIS AND PURPOSE
This amendment to the 1992 Record of Decision (ROD) document presents a
fundamental change to the selected remedial action for the contaminated sludge/soil at the
JFD Electronics/Channel Master Site located in Oxford, North Carolina, chosen in
accordance with CERCLA, as amended by SARA and, to the extent practicable, the
National Contingency Plan. This decision is based on the Administrative Record for this
Site.
The State of North Carolina concurs with the amended remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD Amendment, may
continue to present an imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE MODIFIED REMEDY
.The purpose of this ROD Amendment is to announce a modification of the remedy
for the contaminated sludge and soil, based upon new information including results from
the 1994 and 1995 Treatability Studies and sampling data collected during the Remedial
Design. The amended remedy is more effective for the particular conditions posed by this
Site.
The major components of the modified remedy include:
excavating approximately 1,750 cubic yards of cyanide-impacted sludge;
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Record ol Decision Amendmen1 April 1999
JFD Electronics/Channel Ma.'Sler Sile
transporting the sludge off-site to an appropriate treatment and disposal
facility;
treating the sludge with alkaline chlorination to reduce levels of cyanide;
reducing any hexavalent chromium present in the sludge to trivalent
chromium;
stabilizing the sludge for metals to reach the disposal requirements
established by the disposal facility; and
disposing of the treated and stabilized sludge in the off-site facility.
The contaminated soil which does not require treatment for cyanide, but does
require treatment for metals, would remain on-site for treatment and disposal. The
selected remedy for the contaminated soil would include:
stabilizing the contaminated soil by adding Portland Cement;
sampling and analyzing the cured mixture to confirm that it meets the
treatment levels established in the 1992 ROD for each metal, as well as the
compressive strength requirements of 20 pounds per square inch (psi); and
covering the treated material with topsoil and seeding the areas with a
vegetative cover.
STATUTORY DETERMINATIONS
The modified remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and appropriate
to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable for this Site, and
satisfies the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Richard D. Green, Date
Director, Waste Management Division
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· Record of Decision Amendmenl
JFD Elec1ronics/Channel Master Site
SECTION
TABLE OF CONTENTS
DECISION SUMMARY
1.0 INTRODUCTION
TABLE OF CONTENTS
1.1 Site Name and Location
1.2 Public Participation
1.3 1992 Record of Decision
1.4 Summary of the Circumstances Leading to the
ROD Amendment
1.5 Administrative Record
1.6 Administrative Record Availability
2.0 REASONS FOR ISSUING THE ROD AMENDMENT
2.1 Description of the Sludge and Soil Remedy Selected
April1999
PAGE NUMBER
1
1
1
3
3
3
3.
3
4
in the 1992 ROD 4
2.2 Rationale For Amending the Remedy
in the 1992 ROD 4
2.2.1 Results of the Treatability Study 6
2.2.2 Evaluation of the Supplemental Feasibility Study 7
3.0 OTHER ALTERNATIVES CONSIDERED IN THE 1992
ROD FOR THE SLUDGE AND SOIL
4.0 COMPARISON OF THE SLUDGE AND SOIL REMEDY
IN THE 1992 ROD WITH THE MODIFIED REMEDY
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Record of Decision Amendmen1
JFD Elecironics/Channel Master Site
TABLE OF CONTENTS
SECTION
5.0 EVALUATION OF THE MODIFIED REMEDY
5.1 Overall Protection of Human Health
and the Environment .
5.2 Compliance with ARARs
5.3 Long-term Effectiveness and Permanence
5.4 Reduction of Toxicity, Mobility, or Volume
5.5 Short-term Effectiveness
5.6 Implementability
5.7 Cost
5.8 State Acceptance
5.9 Community Acceptance
6.0 STATUTORY DETERMINATIONS
7.0 RESPONSIVENESS SUMMARY
APPENDIX A -ORIGINAL RECORD OF DECISION
FIGURE 1 -SITE LOCATION MAP
FIGURE 2 -AREAS OF SLUDGE AND SOIL
REQUIRING REMEDIATION
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April 1999
PAGE NUMBER
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Record ol Decision Amendment April 1999
JFD Electronics/Channel Master Site
DECISION SUMMARY
1.0 INTRODUCTION
1.1 SITE NAME AND LOCATION
The 13.09-acre JFD Electronics/Channel Master Site (the "Site") is located
approximately 2 miles southwest of Oxford, Granville County, North Carolina, at the
intersection of Pine Tree Road and Industry Drive. The Site is bordered on the east by a
residential development, and to the south by a railroad spur owned and operated by
Southern Railroad. Figure 1 shows the location of the Site. The main building at the Site
is currently utilized by Hamilton/Avnet Corporation as a distribution warehouse, and a
smaller warehouse on the eastern portion of the property is owned and operated by the
Bandag Corporation.
The Site was operated by JFD Electronics as a manufacturer of television antennas
from 1961 to 1979. The manufacturing processes involved a copper/nickel electroplating
and chrome conversion coating of antenna parts. Wastes generated from the processes,
primarily wastewaters and sludge, contained a number of metals including chromium, lead,
and cyanide. Wastewater from the electroplating and chrome conversion processes were
treated in an on-site treatment plant consisting of interconnecting concrete tanks.
Treatment included the reduction of hexavalent chromium to trivalent chromium. Sludge
generated from the treatment process was disposed in sludge drying beds along the
southern property boundary, and also accumulated in an unlined lagoon.
Channel Master owned the property from 1980 to 1984, during which time they
produced satellite antennae, amplifiers, and boosters at the Site. The North Carolina
Department of Human Resources (now called the North Carolina Department of
Environment and Natural Resources -NCDENR) conducted a Site Inspection at the Site
in 1987. Channel Master conducted a voluntary cleanup of the lagoon in 1987 and 1988,
under the direction and supervision of the North Carolina Department of Human
Resources. The Site was subsequently proposed for inclusion on the National Priorities
List in June 1988 and finalized in October 1989.
EPA initiated a Remedial Investigation/Feasibility Study (RI/FS) at the Site in 1991.
The Record of Decision (ROD) was signed in September 1992. Negotiations for
settlement regarding implementation of the Remedial Design/Remedial Action (RD/RA)
began in October 1992, and a Consent Decree was signed in 1993.
Record ol Decision Amendmenl
JFD Electronics/Channel Masler Sile
H)IS _U.S[HAl'I, DCH_ .. l/20/12
April 1999
FIGURE 1
SIIE_LO_CATION MAP
0 JOO
SCALE IN FEET
2
. .
(:) ...
.··. -----
-~ ~ OJ.I: UOC( HOUSJ/l'c;
rarer u11t --W.IJt.u;c ma: . HDtnn LIii£
600 ,.,.-UCE LJIIE .
-,.. ll1UOAO
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Record of Decision Amendmen1 April 1999
JFO Elecironics/Channel Master Sile
1.2 PUBLIC PARTICIPATION
The public participation requirements of both CERCLA Section 117 and Section
300.435(c)(2)(ii) of the NCP have been satisfied. A press release was issued and fact
sheets were sent to persons on EPA's Site mailing list. A newspaper advertisement
describing the proposed amendment and announcing the public comment period was
placed in the Oxford Ledger on April 13, 1998, and in the Henderson Dispatch on April 14,
1998. A thirty-day public comment period was provided, and EPA has addressed all
comments in the attached Responsiveness Summary.
1.3 1992 RECORD OF DECISION
The original ROD was signed by the Regional Administrator on September 12,
1992. The State of North Carolina concurred with the selected remedy.
1.4 SUMMARY OF THE CIRCUMSTANCES LEADING TO THE ROD
AMENDMENT
Alkaline chlorination was selected as the type of oxidation/reduction treatment
technology for addressing the contaminated sludge and soil at the Site. Treatability
Studies were conducted in 1994 and 1995 to demonstrate that alkaline chlorination could
reduce levels of cyanide in the contaminated sludge and soil to meet the remediation
levels in the 1992 ROD, and to evaluate if alkaline chlorination could be extrapolated to
full-scale application. ·
1.5 ADMINISTRATIVE RECORD
The requirements set forth in Section 300.825(a)(2) of the NCP have been satisfied.
All documents that form the basis for the decision to amend the sludge and soil remedy
have been added to the Administrative Record.
1.6 ADMINISTRATIVE RECORD AVAILABILITY
The Administrative Record is available for viewing by the public during regular
business hours at the following locations:
Richard H. Thornton Public Library
Corner of Main and Spring Streets
Oxford, North Carolina
[phone]
USEPA Region IV Records Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
[phone]
3
. '.,,, . ,, ...
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R8COl'd ol Decision Amendment April 1999
JFO Eleclronics/Channel Mas1er Site
Copies of documents in the Administrative Record may also be obtained from EPA's
Region IV Records Center in Atlanta by writing to the Freedom-of-Information Act (FOIA)
Coordinator and requesting a copy of the JFD Electronics/Channel Master Administrative
Record Index. Choices of documents from the Index may be expressed in additional FOIA
requests.
2.0 REASONS FOR ISSUING THE ROD AMENDMENT
2.1 DESCRIPTION OF THE SLUDGE AND SOIL REMEDY SELECTED IN THE
1992 ROD
Page 98 of the 1992 ROD, Section X.B. -Sludge/Soil Remediation, addresses
approximately 3,000 cubic yards of sludge and soil contamination at the Site. Alternative
#4 includes the excavation of the sludge and soil, on-site treatment with alkaline
chlorination, stabilization, backfilling on-site, and capping. Figure 2 shows the areas of
sludge and soil requiring remediation. One objective of the remedy included preventing
direct contact with and/or ingestion of the contaminated sludge and soil containing metals
above health-based levels. Another objective of the remedy included preventing the
release of the sludge and soil contamination via surface water runoff from the Site,
thereby preventing surface water and sediment contamination in nearby drainage ditches
and streams. Another objective of the remedy was to eliminate the sludge and soil as a
potential source of groundwater contamination.
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2.2
The ROD required the following remediation levels for metals in the sludge and soil:
Levels in the sludge and soil must be reduced to 590 milligrams per liter (mg/I) of
total cyanide in the non-TCLP extract and 30 mg/I of amenable cyanide; and.
Metals levels in the TCLP extract must not exceed the Land Disposal Restrictions
(LDRs) levels provided below:
Cadmium 0.066 mg/I
Chromium 5.2 mg/I
Lead 0.51 mg/I
Nickel 0.32 mg/I
Silver 0.072 mg/I
RATIONALE FOR AMENDING THE REMEDY IN THE 1992 ROD
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Record of Decision Amendmenl
JFO Eleclronics/Channel Mesler Site
NSIOO
ow,a. IUSTCI IUllf IUllDIIIC
April 1999
'
FIGURE 2
AREAS OF SLUDGE AND SOIL REQUIRING REMEDIATION
. -·•····· -··--·--· . ·-----··-· -·----· . -'" ... ·-···-· ······-·
I.IJCOA'"YUDIDUSE
:-:-:-: .·.·.·.
TU.lTMtllT
'""' rxil~!~/;
... ----~------
0 I 00 200
N4800 SCALE IN FEET
ZOJIS JC·IS.OCN 4/4/92
5
SllllCE DITiltG.PJTS U"10XIIU.fEI
AW, TO IE Eitm.m TCI I n
AW. To IE OC,I.Y.lTEO TO S rT
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Record of Decision Amendmen1 April 1999
JFD Electronics/Channel M~ler Site
2.2.1 Results of the Treatability Study
As required in the 1992 ROD, a treatability study was conducted in 1994 to evaluate
the effectiveness of alkaline chlorination in reducing the levels of cyanide in the sludge
and soil. The results of this initial treatability study indicated that cyanide oxidation and
reduction by alkaline chlorination under the conditions tested was not sufficient to meetthe
remediation levels in the 1992 ROD. Total cyanide concentrations ranged from 4,600
milligrams per kilogram (mg/kg) to 5,500 mg/kg before treatment. Following treatment, the
levels of cyanide ranged from 1,400 mg/kg to 1,900 mg/kg, well above the remediation
level of 590 mg/kg total cyanide established in the 1992 ROD. Based on a review of the
treatability study data, EPA concluded, "It is likely that the cyanide cannot be completely
oxidized because of the formation of iron and nickel complexes".
After reviewing the Treatability Study in 1994, EPA recommended that additional
treatabilitytesting be conducted to evaluate alternative treatment technologies. Additional
testing of alkaline chlorination was performed during the summer of 1994. The results
from this additional study indicated the remediation levels required in the 1992 ROD for
cyanide were achieved using alkaline chlorination; however, due to the apparent oxidation
of chromium during the alkaline chlorination process, the levels of chromium in the sludge
did not meet the remediation levels in the 1992 ROD.
In 1995, after evaluating and screening a number of potential technologies,
Geraghty & Miller recommended conducting further testing of the sludge using hot"alkaline
chlorination and low temperature thermal desorption. The results of the 1995 study
indicated that both hot alkaline chlorination and low temperature thermal desorption could
be used to successfully remediate cyanide to reach the remediation levels required in the
1992 ROD. However, both treatment processes exhibit technological limitations which
may require additional treatability or pilot scale testing. These limitations may inhibit full
scale implementation of the technology. The two technologies were summarized as
follows:
•
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Hot alkaline chlorination required a high chemical dose and a moderately long
treatment time, and produces a significant amount of hexavalent chromium during
the cyanide oxidation process. Treatment of cyanide by hot alkaline chlorination
would require cyanide oxidation at an elevated pH, reduction of chromium at a low
pH, and subsequent neutralization and soil stabilization .
Treatment of cyanide by low temperature thermal desorption also removed cyanide
to the remediation levels; however, some oxidation of chromium occurred.
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Record o1 Decision Amendment April 1999
JFD Elecironics/Channel Master Site
2.2.2 Evaluation of the Supplemental Feasibility Study
Based on the treatability studies conducted in 1994 and 1995, Geraghty & Miller
conducted a Supplemental Feasibility Study (SFS) in 1996. The objectives of the SFS
were as follows:
•
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supplement the initial Feasibility Study with a review and assessment of
alkaline chlorination and thermal desorption, as well as alternate treatment
technologies for cyanide and metals in the sludge and soil;
develop detailed cost estimates for the hot alkaline chlorination and thermal
desorption technologies retained in this assessment; and
recommend a specific treatment technology which can achieve the
remediation levels required in the 1992 ROD for cyanide and metals.
3.0 OTHER ALTERNATIVES CONSIDERED IN THE 1992 ROD FOR THE SLUDGE
AND SOIL
The 1992 Feasibility Study evaluated five remedial alternatives for addressing
the contaminated sludge and soil at the Site. The following paragraph provides a brief
evaluation of the four alternatives not selected in the 1992 ROD.
The first alternative included a "No Action" alternative. The 1992 Feasibility
Study determined that the "No Action" alternative would not be protective of human
health and the environment. Therefore, the "No Action" alternative was not acceptable
to EPA.
The second alternative involved the use of fencing, warning signs, deed
restrictions, and capping as a means of providing protection to human health and the
environment. Using institutional actions and capping the Site would reduce the mobility
of the sludge and soil, but would not reduce the toxicity or volume of the sludge and
soil. Leaving the sludge and soil on the Site would require implementing deed
restrictions for future land use and maintaining the warning signs and fencing. The
long-term effectiveness of this alternative is questionable.
The third alternative would involve excavating and transporting the sludge and
soil off-site for treatment and disposal. While this remedy would effectively remove the
sludge and soil from the Site, the storage, transportation and disposal of the
contaminated sludge and soil would be subject to RCRA and DOT regulations.
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Record of Decision Amendment April 1999
JFO Eleclronics/Channel Master Si1e
The fifth alternative involved excavation and on-site treatment with vitrification
and subsequent backfilling and capping. This alternative would be a permanent
remedy that would reduce the risks associated with the sludge and soil at the Site.
However, vitrification is a new innovative technology, and there is limited data
available to evaluate this technology's effectiveness.
4.0 COMPARISON OF THE SLUDGE AND SOIL REMEDY IN THE 1992 ROD
WITH THE MODIFIED REMEDY
The original remedy in the 1992 ROD required approximately 3,000 cubic yards
of contaminated sludge and soil to be excavated from the eleven sludge drying beds
and surrounding areas. Figure 2 shows the areas identified in the 1992 ROD requiring
remediation. Verification sampling would be performed during the excavation to ensure
that the areas identified with sludge contamination have been excavated. The 1992
ROD required the sludge and soil be stockpiled, slurried, and transferred to a treatment
vessel where the alkaline chlorination process would take place. A cleanup
verification plan would be prepared during the design phase to ensure that the
appropriate number of samples are collected to prove that the Site has been
remediated.
Cyanide and TCLP analysis would be performed during the treatment process to
ensure that the alkaline chlorination treatment process is achieving the remediation
levels established in the 1992 ROD. Following the alkaline chlorination process, the
sludge and soil would be stabilized with a chemical reagent such as Portland Cement.
The treated sludge and soil would then be backfilled into the excavated areas and
capped. For detailed descriptions of Alternative #4, refer to Section 6.5.2 of the 1992
Feasibility Study, as well as Section VIII B, page 82, and Section X, page 98, of the
1992 ROD.
The modified remedy requires treatment of 3,000 cubic yards of contaminated
sludge and soil, including 1,750 cubic yards of cyanide-impacted sludge requiring
cyanide treatment and subsequent metals stabilization, and 1,250 cubic yards of soil
requiring metals stabilization. The 1,750 cubic yards of contaminated sludge would be
excavated and transported to an approved off-site facility for treatment and disposal.
The 1,250 cubic yards of contaminated soil would be stabilized on-site, backfilled into
the excavated areas, covered with soil, and seeded with vegetative cover. The
remediation levels for the soil in the modified remedy are the same as the remediation
levels in the 1992 Record of Decision.
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Record of Decision Amendmen1 April 1999
JFD Eleclronics/Channel Mas1er Si1a
5.0 EVALUATION OF THE AMENDED REMEDY
5.1 Overall Protection of Human Health and the Environment
The remedy in the 1992 ROD provided a permanent treatment thereby
eliminating the potential risks associated with the dermal contact and ingestion of the
sludge and soil. The remedy would also eliminate the potential for the contaminants in
the sludge and soil from migrating off-site via surface water runoff and adversely
impacting the nearby drainage ditches and streams.
Similar to the original remedy, the modified remedy would provide a permanent
treatment thereby eliminating the potential dermal contact and ingestion of the sludge
and soil. The modified remedy would also eliminate the potential for contaminants in
the soil from migrating off-site via surface water runoff and adversely impacting the
nearby drainage ditches and streams. For additional information regarding the
amended remedy, please refer to the Supplemental Feasibility Study located in the
Administrative Record files (see Section 1.6 for the locations). ·
5.2 Compliance with ARARs
The ARARs governing the implementation of Alternative #4, as described in the
· 1992 Feasibility Study, would apply to the excavation, treatment, and disposal of the
sludge and soil, reclamation and capping of the excavated areas, and the monitoring
activities. The Land Disposal Restrictions (LDRs) [40 CFR Part 268] are not an ARAR
for the on-site treatment of the soil as long as the excavated RCRA wastes are not
removed from the areas of concern during the remedial action. All appropriate North
Carolina Solid Waste Disposal Regulations [NCAC, Title 15A, Ch. 13B] identified in the
1992 ROD would be an ARAR for this remedy.
Excavating and transporting the sludge off-site for treatment and disposal would
trigger Department of Transportation regulations for the transportation of RCRA
hazardous waste [49 CFR Parts 107, 171-179], and RCRA Land Disposal Restrictions
(LDRs) because the sludge is characterized as F006 and F019 RCRA hazardous waste
[40 CFR Part 268]. The off-site treatment and disposal facility would be responsible for
the appropriate RCRA permits as a Treatment, Storage, and Disposal facility [40 CFR
Part 262]. The Occupational Safety and Health Regulations (OSHA), and the North
Carolina Solid Waste Disposal Regulations [NCAC, Title 15A, Ch. 13B], would be an
ARAR for this remedy.
5.3 Long-term Effectiveness and Permanence
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Record ol Decision Amendment April 1999
JFO Electronics/Channel Master Site
Treatability Studies were conducted in 1994 and 1995 to evaluate the
effectiveness of the alkaline chlorination process in reducing the toxicity, mobility, and
volume of contaminants in the sludge and soil. The results indicated that alkaline
chlorination would not reduce the levels of cyanide in the sludge to meet the.
remediation levels established in the 1992 ROD. Stabilization was not conducted on
the sludge during the 1994 and 1995 Treatability Studies since the alkaline chlorination
treatment process was not successful.
The off-site treatment and disposal of the sludge would permanently and
effectively remove the sludge from the JFD Electronics/Channel Master Site.
The contaminated soil would be stabilized on-site to meet the remediation levels
established in the 1992 ROD. Sampling and analyzing the stabilized material for TCLP
constituents would be required to verify the effectiveness of the remedy.
5.4 Reduction of Toxicity, Mobility, or Volume
The 1994 and 1995 Treatability Studies indicated that the levels of cyanide in
the sludge were not reduced to the remediation levels established in the 1992 ROD.
Therefore, the alkaline chlorination technology proved to be ineffective in reducing the
toxicity of the sludge.
The volume of haza.rdous waste would be reduced at the Site by excavating and
transporting the sludge off-site to a treatment and disposal facility. Stabilizing the
contaminated soil on-site would reduce its toxicity and mobility. However, the volume
of the soil would increase due to the addition of a chemical reagent such as. Portland
Cement.
5.5 Short-term Effectiveness
The 1994 and 1995 Treatability Studies indicated that an extremely large
volume of reagent would be needed to complete the alkaline chlorination process on-
site as part of the original 1992 remedy. The presence of large volumes of reagent on-
site would present potential risks to workers and nearby residents. The Treatability
Studies also indicated that the on-site treatment process could involve unnecessary
risks due to the potential for cyanide gases being generated during the treatment
process.
By comparison, there is potential risk to the nearby community and remedial
workers due to the potential for direct contact and inhalation of the contaminants in the
sludge and soil during the implementation of the amended remedy. Potential risks to
the community would also be of concern during transportation of the sludge along
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Record ol Decision Amendment • April 1999
JFD Electronics/Channel Master Site
public roads and highways to the treatment and disposal facility. An implementation
plan and health and safety plan will be required as part of the Remedial Design in order
to minimize any potential impacts to nearby residents or to remedial workers performing
the excavation, treatment, and disposal.
Confirmatory sampling and analysis of the excavated areas would be performed
to ensure that all contamination has been excavated to meet the remediation levels
specified in the 1992 ROD. Likewise, the stabilized soil will be analyzed to ensure that
no leaching occurs above the remediation levels established in the 1992 ROD.
5.6 Implementability
The 1994 and 1995 Treatability Studies indicated that the use of alkaline
chlorination for treating the sludge and soil on-site would not be technically feasible.
However, the on-site treatment of the contaminated soil using stabilization would be
readily implementable.
The excavation and off-site treatment and disposal of the sludge would be
readily implemented with no significant operational or administrative difficulties.
Permitted treatment and disposal facilities are available with the necessary equipment
and personnel to complete the treatment process. Stabilization of contaminated soil is a
proven technology; therefore, the on-site treatment of the contaminated soil would be
readily implementable. ·
5.7 Cost
The 1992 ROD estimated the total present worth cost of the original sludge/soil
remedy to be $1,211,000. However, based on the 1994 and 1995 Treatability Studies,
the Supplemental Feasibility Study estimated the total present worth cost of the original
sludge/soil remedy to be $5,048,577.
By comparison, the present worth total cost of the modified remedy, including
excavating and transporting the sludge off-site for treatment and disposal, and
stabilizing the soil on-site, is $2,582,385.
5.8 State Acceptance
The State of North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR), now called the NCDENR, concurred with the remedy selected
in the 1992 ROD.
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Record of Decision Amendment April 1999
JFD Elecironics/Channel Master Si1e
The NCDENR concurs with this modified remedy.
5.9 Community Acceptance
The community generally accepted the original remedy in the 1992 ROD. See
the Responsiveness Summary, which is APPENDIX B, to the 1992 ROD.
By comparison, the community generally accepts the amended remedy. The 30-
day public comment period was held from April 14, 1998 to May 13, 1998, and no
written comments were received by EPA on the amended remedy.
6.0 STATUTORY DETERMINATIONS
The modified remedy satisfies CERCLA Section 121; the remedy is protective of
human health and the environment, complies with ARARs, is cost effective, and utilizes
permanent solutions and alternative treatment technologies to the maximum extent
practicable. Preference for treatment as a principal element is satisfied by other
aspects of the overall remediation of the JFD Electronics/Channel Master Site.
7.0 RESPONSIVENESS SUMMARY
EPA has addressed all comments in the attached Responsiveness Summary.
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Record ol Decision Amendmen1 April 1999
JFO El8C1ronics/Channel Mas1er Si1e
APPENDIX A
ORIGINAL RECORD OF DECISION
I • ARCADIS GERAGHTY&MILLER
Mr. McKenzie Mallary
Remedial Project Manager
United States Environmental Protection Agency
RECEIVED
AUG 19 1998
I 00 Alabama Street, SW c --, .. ,r'UND SECTION
Atlanta, Georgia 30303-3104
Subject:
Soils/Sludge Treatment Technology, JFD Electronics/Channel Master Site, Oxford,
North Carolina.
Dear Mr. Mallary:
In our letter dated May 13, 1998, we requested the U.S. Environmental Protection
Agency (USEPA) to provide flexibility in the Record of Decision (ROD) Amendment
to use treatment methods other than alkaline chlorination for cyanide-impacted
soils/sludge at the site. As you requested, ARCADIS Geraghty & Miller reviewed
other potential treatment technologies. Based on our review of available technologies
and discussions with treatment vendors, incineration is the only full-scale treatment
technology currently available at fixed (off-site) facilities. However, the cost for
incineration option will be significantly higher than that of the alkaline chlorination.
Therefore, we recommend USEPA to proceed with ROD Amendment including
Alternative 3 in the Supplemental Feasibility Study (SFS) report (Off-Site Alkaline
Chlorination of Cyanide and On-Site Metals Stabilization) as the selected option. This
alternative includes the following steps:
I. Excavation and transfer of soils/sludge that exceed the remediation goals for
cyanide to a suitable treatment facility;
2. Treatment of soils/sludge containing cyanide (from Step I) by alkaline
chlorination at an approved off-site facility;
3. Reduction and stabilization of chromium (if present) in the soils/sludge from Step
2;
4. Disposal of treated soils/sludge from Step 3 at a RCRA Subtitle D landfill;
5. On-site stabilization of soils impacted with metals (no cyanide).
6. Installation of topsoil over the stabilized soils (Step 5) and seeding to establish a
vegetative cover.
Our ref.:
NC0202.140/mallry13.doc
ARCADIS Geraghty & Miller, Inc.
2840 Plaza Place
Suite 350
Raleigh
North Carolina 27612
Tel [phone]
Fax [phone]
ENVIRONMENTAL
Raleigh,
18 August 1998
Contact:
Nanjun Shetty
Extension:
335
' • •
ARCADIS GERAGHTY&MILLER
Upon review of this letter, if you have any questions or comments, please contact us at
[phone].
Sincerely,
ARCADIS Geraghty & Miller, Inc. w lt~ ·ii ~ J]
Nanjun Shctty, P.E.
Senior Engineer
Copies
Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
David Mattison, NCDENR
Our ref ..
g: a project\Jfdcha n n\NC0202.012\correspo/mallry 13. doc
William H. Doucette, Ph.D., L.G
Associate/Project Coordinator
Page:
2/2
~F:j>~OSED AMENDrJ.,T TO THI; 1992
. . .. ::::,: AECOM OF DECISION
SUPEr:wuJF:D ELECTRONICS/CHANNEL
MASTER SUPERFUND SITE
Oxford, Granville County, North Carolina
April 1998
This fact sheet is not to be considered a technical document, but has been prepared in order to provide the public with a basic
understanding of activities that have been occurring over the past few years.
BRIEF HISTORY
The Site is approximately 13 acres in size and is
located approximately 2 miles southwest of Oxford at
the intersection of Pine Tree Road and Industry
Drive. The Site was operated by JFD Electronics
from 1961-1979 in the manufacturing of television
antennas. The manufacturing processes involved a
copper/nickel electroplating and chrome conversion
coating of antenna parts. Wastes generated from the
processes, primarily wastewater and sludge,
contained a number of metals including chromium,
lead, and cyanide. Wastewater from the electro-
plating and chrome conversion processes were
treated in an on-site treatment plant. Sludge
generated from the treatment process was disposed
of in sludge drying beds along the southern property
boundary and also in an unlined lagoon. ;
Channel Master owned the property from 1980 to
1984. The produced satellite antennae, amplifiers,
and boosters. The North Carolina Superfund Office
conducted an inspection of the Site in 1987. As a
result of their findings Channel Master conducted a
voluntary cleanup of the lagoon in 1987 and 1988.
The Site was proposed to be placed on the National
Priorities List (NPL), and was officially listed on the
NPL in October 1989.
EPA initiated a Remedial Investigation/Feasibility
Study (RI/FS) of the Site in 1991. The Record of
Decision (ROD) was signed in 1992 selecting the
treatment remedy to be used to clean up Site
contaminants. EPA conducted negotiations with the
companies for them to implement the selected
rern.,..:;1 . In 1993 the parties signed a Consent
Decree agreeing to implement the Remedial Design
and Remedial Action (RD/RA) phase of the process.
SUMMARY OF CIRCUMSTANCES LEADING
TO THIS ROD AMENDMENT
The ROD required on-site treatment of approximately
3,000 cubic yards of contaminated sludge and soil.
Two objectives oi the remedy inciuded preventing
direct contact with and/or ingestion of !'ie
contaminants, and preventing the release of the
sludge and soil contamination via surface water
runoff from the Site into nearby drainage ditches and
streams.
The treatment technology selected for addressing the
sludge and soil contamination at the Site included
excavation, on-site treatment with Alkaline
Chlorination, stabilization, backfilling and capping.
The contaminants of concern are: cyanide, cadmium,
chromium, lead, nickel and silver.
Following development of the design of the treatment
system, a treatability study was conducted in 1994/95
to determine if the process would reduce the levels
of contaminants to meet the remediation levels
** PUBLIC MEETING **
A Dl:111 ,:,1 1 00~ .. ;. .. ··--. ' . ---
PUBLIC WORKS ASSEMBLY
227 W. McClanahan St.
Oxford, NC
TIME: 7:00 pm
30-DA Y PUBLIC COMMENT
PERIOD:
APRIL 14 -MAY 13, 1998
• • stated in the 1992 ROD. Results of the treatability • sampling and analyzing the cured mixture to confirm that it meets the treatment levels
established in the 1992 ROD for each metal,
as well as the compressive strength
requirements of 20 pounds per square inch.
study indicated that the remedy was not sufficient to meet the stated levels. ·
Based on the results of the 1994 an;:; , ::195 Treatability studies, additional treatability studies were conducted on hot alkaline chlorination and thermal desorption. Subsequently, a Supplemental Feasibility Study (SFS) was developed in 1996. The objectives of the SFS were:
• review and assess hot alkaline chlorination and thermal desorption, as well as alternate treatment technologies for cyanide and metals in the sludge and soil;
• develop detailed cost estimates of these technologies; and
• recommend a specific treatment technology which can achieve the remediation levels required in the 1992 ROD for cyanide and metals.
DESCRIPTION OF THE MODIFIED REMEDY
Based upon information gathered from the initial Feasibility Study, the Supplemental Feasibility Study and sampling data collected durir;i the Remedial Design, the major components of the modified remedy include:
•
•
•
•
' excavating approximately 1,750 cubic Iyards of cyanide-impacted sludge;
transporting the sludge off-Site to an appropriate treatment and disposal facility;
treating the sludge with alkaline chlorination
to reduce levels of cyanide and to reduce hexavalent chromii.:m to trivalent chromium;
stabilizing the sludge for metals to reach the remediation levels established in the 1992 ROD; and
• placing the treated and stabilized sludge in the disposal facility off-Site.
The contaminated soil which does not require treatment for cyanide, but does require treatment for metals. would remain on-Site for treatment and disposal. · Ti,e selected remedy for the contaminated soil would inc:u;:ie:
• stabilizing the contaminated soil by adding Portland Cement; and
The modified remedy is protective of human health and the environrr:ent, complies with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial ·action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment tecilnologies to the maximum extent practicable for this Site, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element.
For more details concerning this proposed Amendment to the 1992 Record of Decision, the technical documentation has been placed in the Information Repository located in the :
Richard H. Thornton Public Library
Corner Main and Spring Streets
Oxford, North Carolina
[phone]
NEED MORE INFORMATION?
For technical information please contact:
McKenzie (Ken) Mallary, Project Manager
U.S.E.P.A., Region 4, At1• ·-
1-800-435-9233 ext.
To have your name placed on the mailing list, to notify us of a change of address, or to request copies of literature, please contact:
Diane Barrett, Community Involvement
U.S.E.P .A., Region 4, Atlanta
1-800-435-9233 ext. 28830
; •
JAMES 8. HUNT JR.
GoVERNOR
•
Mr. McKenzie Mallary
Superfund Branch
Waste Management Division
US EPA Region IV
6 J Forsyth Street, l J 1h Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
April 6, 1998
RE: Amendment to the 1992 Record of Decision
Remedial Alternative Selection
JFD Electronics/Channel Master NPL Site
Oxford, Granville County
Dear Mr. Mallary:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the above document for the JFD
Electronics/Channel Master National Priority List Site. The Superfund Section offers the
attached comments.
The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely,
7)J61Jbf
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE 919•733-4996 FAX [phone] AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER
,•
' ',
Mr, McKenzie Mallary
April 6, 1998
Comments
Page I
•
AMENDMENT TO THE 1992 RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Table of Contents
•
I, The title for Section 2, I is given as Description of the Sludge and Soil Remedy Selected in
the ROD, However, the title for Section 2, I is Description of the Remedy Selected in the
ROD, Please clarify this discrepancy,
2, The page number citation for Section 6,0 -Statutory Determinations should be page 12,
Please correct this oversight
3, The title for Figure 2 is given as Areas with Sludge and Soil to be Remediated, However, the
title for Figure 2 is Areas of Sludge and Soil Requiring Remediation, Please clarify this
discrepancy,
Section I.I Site Name and Location
4, The third sentence of the third paragraph of this section should state ", , , of the North
Carolina Department of Environment and Natural Resources (NC DENR),"
Section 1.2 Public Participation
5, This section states that "A newspaper advertisement describing the proposed amendment and
announcing the public comment period was placed in a local newspaper, A thirty-day public
comment period was provided, and EPA has addressed all comments in the attached
Responsiveness Summary," However, Section 5,9 and Section 7,0 indicate that the public
comment period has not been held as of the drafting ofthis ROD amendment Please clarify
these discrepancies and make all appropriate modifications, Additionally, please provide the
name of the newspaper as well as the dates in which the advertisement was placed, if such
activities have been completed,
.. I '
Mr. McKenzie Mallary
April 6, 1998
Comments
Page 2
• •
Section 2.1 · Description of the Remedy Selected in the 1992 ROD
6. The second paragraph of this section should state the following:
"The ROD required the following remediation levels in the sludge and soil:
* Levels in the sludge and soil must be reduced to 590 milligrams per liter
(mg/I) of total cyanide in the non-TCLP extract and 30 mg/ml of amenable
cyanide; and,
* Metal levels in the TCLP extract must not exceed the Land Disposal
Restriction (LDR) levels provided below:
Cadmium 0.066 mg/ml
Chromium 5.2 mg/ml
Lead 0.51 mg/ml
Nickel 0.32 mg/ml
Silver 0.072 mg/ml"
Section 5.0 Evaluation of the Amended Remedy
7. Please move the heading for Section 5.0 and Section 5.1 to the following page (Page 9).
Please make the appropriate modifications to the Table of Contents.
Section 5.5 Short-term Effectiveness
8. The word "unnecessary" is misspelled in the last sentence of the first paragraph of this section.
Please correct this oversight.
Section 5.8 State Acceptance
9. Please restate the first sentence of this section to include the following: "The State ofNorth
Carolina Department of Environment, Health and Natural Resources (NC DEHNR), now
called the NC DENR, concurred with the remedy selected in the 1992 ROD."
NORTH SUPERFUND APR 02'98 11 :38 No.007 P.01 •
AMENDMENT TO THE
1992 RECORD OF DECISION
_;EDIAL ALTERNATIVE SELECTION
'~~;;;:;,
) ' ,I
JFD ELECTRONICS/CHANNEL MASTER SITE
OXFORD, GRANVILLE COUNTY, NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA.GA
\
NORTH SUPERFUND ID: APR 02'98 11 :39 No.007 P.02 • • I
BM!Ord ol Deelslon Amendment MernblRPA: JFD Elt>dt0nlo<ICl1"nnel MM1or Silo
-~• DECLARATION FOR THE iiJf RECORD OF DECISION AM~NDMENT
Fundamental Change to the Selected Sludge and Soil Remedy
In the 1992 Record ot Decision
SIU; NAME AND LOCATION
JFD Electronics/Channel Master Site
Oxford, Granville County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This amendment to the 1992 Record of Decision (ROD) document presents a _fundamental change to the selected remedial action for the contaminated sludge/soil at the JFD Electronics/Channel Master Site located In Oxford, North Carolina, chosen In . acc~dance wit,11 CERCLA, as amonded by SARA and, to the extent practicable, the .• ,_~fS~~al C~n~ncy Plan. This dec'.~ion Is based on the Administrative Record for this
;,-~ ?'~ :,~~ .' ( ,, .. ~~ /
-> Th~!State of North Carolina concurs with the amended remedy.
AS_SESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response action selected in this ROD Amendment. may continue to present an imminent and substantial endangerment to public health, welfare. or the environment.
DESCRIPTION QE THE MODIFIED REMEDY
The purpose of this ROD Amendment is to announce a modification of the remedy for the contaminated sludge and soil, based upon new Information including results from _ the 1994 and 1995 Treatablllty Studies and sampling data collected during the Remedial Design, so that the amended remedy is more effective for the particular conditions posed by this Sile .
. ~ !~ The_m~components of the modified remedy Include: /,-"1 ✓~ "'"',;i; ( I ,-do :1 ;'
-> 1J 1 -
NOR'TH SUPERFUND ID: APR 02'98 11 :39 No.007 P.03 • • I
Ramnt of Qeoklan Atnendmanl Mw:rb 1PM
;,~· -Nl~arSl1o ' ,, ,Jf.""'' -. -.,.:t_✓,, .. ,. ' _,
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-;~cavating approximately 1,750 cubic yard~ of cyanide-impacted sludge;
transporting the sludge off-site to an appropriate treatment and disposal
facility;
treating the sludge with alkaline chlorination to reduce levels of cyanide and
to reduce hexavalent chromium to trivalent chromium;
stabilizing the sludge for metals to reach the remediation levels established
in the 1992 ROD; and
placing the treated and stabilized sludge in the disposal facility off-site.
The contaminated soil which does not require treatment for cyanide, but does require treatment for metals, would remain on-site for treatment and disposal. The selected remedy for the contaminated soil would include:
i;tflizing the contaminated soil by adding Portland Cement:
--~ :J'.~i!mpllng and analyzing the cured mixture to confirm that It meets the '.~teatment levels established In the 1992 ROD for each metal, as well as the ' ~ compressive strength re,quirements of 20 pounds per square Inch (psi); and I
covering the-treated material with topsoil and seeding the areas with grass.
STATUTORY DETERMINATIONS
The modified remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable for this Site, and satisfies the statutory preference for remedies that t'.ilmploy treatment that reduces toxicity, mobility, or volume as a principal element.
' ..:. ,; :,.
~ :·.~ -~''
NORTH SUPERFUND ID: APR 02'98 11 :39 No.007 P.04 • \
TABLE OF CONTENTS
SECTION
TABLE OF CONTENTS
DECISION SUMMARY
1.0 INTRODUCTION
1.1 Site Name and Location
1.2 Public Participation
-1.3 1992 Record of Decision
_ . ,; J~ 1.4 s_~inary of the Circumstances Leading to the
:1 ·~~ -""ROD Amendment ;.-.:.-C ,.: tW';; ' 1 -~~~minlstratlve Record
,-_,. 1.s':f'idministrative Record Avallablllty
2.0 REASONS FOR ISSUING ntE ROD AMENDMENT
I
•
2.1 Description of the Sludge and Soll Remedy Selected
MIM!b100G
PAGE NUMBER
1
1
1
3
3
3
3
3
4
In the 1992 ROD 4
2.2 Rationale For Amending the Remedy
In the 1992 ROD 4
2.2.1 Results of the Treatablllty Study 4
2.2.2 Evaluation of the Supplemental Feaslblllty Study 6
3.0 OTHER ALTERNATIVES CONSIDERED IN THE 1992
ROD FOR THE SLUDGE AND SOIL
4.0 COMPARISON OF THE 1992 SLUDGE AND SOIL REMEDY
_ WITH THE MODIFIED REMEDY
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ID: • APR 02'98 11 :40 No.007 P.05 •
JFD Eloctronloo/Chonnol Masttr Stt• Memb19M
TABLE OF CONTENTS
SEQIJON PAGE NUMBER
5.0 EVALUATION OF THE MODIFIED REMEDY 8
' 6.1 Overall Protection of Human Health
and the Environment 8
5.2 Compllance with ARARs 9-
5.3 Long-term Effecilveness and Permanence 9
5.4 Reduction of ioxlclty, Mobility, or Volume 10
~ 6.6 S~-~-term Effectiveness 10 , ~ ;z . 6.6 J11J~lftmentablllty 11
-"· , 5.7-C~tt 11 /,:J{._c: A\"
5,~j•ate Acceptance 11
> 5.9 Community Acceptance 11 C .•
y, ' , ·~
6-0 STATUTORY DETERMINATIONS 11 ~,, _;,-t
7.0 RESPONSIVENESS SUMMARY 12
I
APPENDIX A· ORIGINAL RECORD OF DECISION 13
FIGURE 1 -SITE LOCATION MAP 2
FIGURE 2 • AREAS WITH SLUDGE AND SOIL
TO BE REMEDIATED 5
·11-
ID: APR 02'98 11:40 No.007 P.06 • • \
''·J -· ] '
Raoord of Decfl;lon Amendment
JFD Eleclronlcs/Ohart""I Moat,,r SHe Mar,;h1998
DECISION SUMMARY
1 .O INTRODUCTION
1.1 SITE NAME AND LOCATION
The. 13.09-acre JFD Electronics/Channel Master Site (the "Site") Is located
approximately 2 miles southwest of O11ford, Granville County, North Carolina, at the
intersection of Pine Tree Road and Industry Drive. The Site is bordered on the east by a
_ _i;esidential deveJopment, and to the south by a railroad -spur owned and operated by
. "';;,,~¢:o}!,hern Rail~d. Figura 1 shows the location of the Sita. The main building at the Site
/,:!Js}lcurrently,ljJJllzed by Hamilton/Avnet Corporation as a distribution warehouse, and a
'smaller ~~1pi3Gse on the eastern portion of the property Is owned and operated by the
Bandag Corporation. C
The Site was operated by JFD Electronics as a manufacturer of television antennas
from 1961 to 1979. The manufacturing processes Involved a copper/nickel electroplating
and chrome conversion coating of antenna parts. Wastes generated from the processes,
primarily wastewaters and sludge, contained a number of metals including chromium, lead.
and cyanide. Wastewater from the electroplating and chrome conversion processes were
treated In an on-site treatment plant consisting of interconnecting concrete tanks.
Treatment included the reduction of hexavalent chromium to trivalent chromium. Sludge
generated from the treatment process was disposed in sludge drying beds along the
southern property boundary, and also accumulated in an unlined lagoon.
Channel Master owned the property from 1980 to 1984, during which time they
produced satellite antennae, amplifiers, and boosters at the Site. The North Carolina
Department of Human Resources (now called the North Carolina Department of
Environment and Natural Resources) conducted a Site Inspection at the Site In 1987.
_ Channel Maste,;,.conducted a voluntary cleanup of the lagoon In 1987 and 1988, under the
• 0·;J(~i~ion and~pervision of the North Carolina Department of Natural Resources. The
· · /:j"-}~it~ was subsitj\Jently proposed for inclusion on the National Priorities List in June 1988
"> 'and finali,~Ff Ootober 1989. ·
0
.
EPA initiated a Remedial Investigation/Feasibility Study (RI/FS) at the Sito in 1991.
The Record of Decision (ROD) was signed in September .1992. Negotiations for
settlement regarding implementation of the Remedial Design/Remedial Action (RD/RA)
began In October 1992. a.nd a Consent Decree was signed in 1993.
1
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NORTH SUPERFUND ID: • APR 02 '98 11: 41 No. 007 P. 08~12 •
tteoord er PR¢21on Amaodro,m
JFD Eltdtonlc&'Channel Master She MW1998
1.2 PUBLIC PARTICIPATION
The public participation requirements of both CERCLA Section 117 and Section
300.43(j(c)(2)(11) of the NCP have been satisfied. A press release was Issued and fact
sheets were sent to persons on EPA's Site mailing list. A newspaper advertisement
~~esgi:it>ing thji:pr. oposed amendment and announcing the public comment period was , ';,17PJ~ in a !~~fnewspaper. A thirty-day public comment period was provided, and EPA
/.:; ~~tiaf"addr~~~td~I comm9nts in th8 attached R8sponslveness Summary.
)'·
'" 1.3' · '· 1992 RECORD OF DECISION s .
The original ROD was signed by the Regional Administrator on September 12.
1992. The State of North Carolina concurred with the selected rem~y.
1.4 SUMMARY OF THE CIRCUMSTANCES LEADING TO THE ROD
AMENDMENT
Alkaline chlorination was selected as the type of oxidation/reduction treatment
technology for addressing the contaminated sludge and soil at the Site. Treatability
Studies were conducted In 1994 and 1995 to demonstrate that alkaline chlorination could
reduce levels of cyanide In the contaminated sludge and soil to meet the remediation
levels in the 1992 ROD, and to evaluate if alkaline chlorination could be extrapolated to
fuU-scale application. '
1.5 ADMINISTRA JIVE RECORD · ".;J2ti The_r_!!~ements set forth In Section 300,825(a)(2) of the NCP have been salisflecl.
/,-" ~:.:All docurnentf;1pat form the basis for the decision to amend the sludge ancl soil have been
added to;;~dministratlve Record. C
1.6 ADMINISTRATIVE RECORD AVAILABILITY
Tho Admlnistrativo Rocord Is avallablo for viowing by the public during regular
business hours at tho following locations: ·
Richard H. Thornton Public Library
Corner of Main and Spring Streets
Oxford. North Carolina
[phone]
USEPA Region IV Records Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
( 404) 562-8946
3
NORTH SUPERFUND ID: RPR 02'98 11 :42 No.007 P.09 • •
Booont o1 R'®loo Amend®n1 MJlot!1893
JFD ElaclmniaJChamel Mest&r Sits
Coples of documents in the Administrative Record may also be obtained from EPA's
Region IV Records Center l_n Atlanta by writing to the Freedom-of-lnformatlon Act (FOIA)
Coo[Cllnator and requesting a copy of the JFD Electronics/Channel Master Administrative
. ". ;fi°jl~rd lndex~J!.oices of documents from the Index may be expressed in additional FOIA
.4."' trasts. · -~
,1,-]-2 . -~~ , l•w;.dt :!I'>'
2.0 REASONS FOR ISSUING THE ROD AMENDMENT ~ C
2.1 DESCRIPTION OF THE REMEDY SELECTED IN THE 1992 ROD
Page 98 of the 1992 ROD, Ssction X.B. -Sludge/Soil Remediation, addresses
approximately 3,000 cubic yards of sludge and soil contamination at the Site. Alternative
#4 includes the excavation of the sludge and soil, on-site treatment with alkaline
chlorination, stabilization. backfilling on-site, and capping. Figure 2 shows the areas of
sludge and soil requiring remediation. One objective of the remedy included preventing
direct contact with and/or ingestion of the contaminated sludge and soil containing metals
above health-based levels. Another objective of the remedy included preventing the
release of the sludge and soil contamination via surface water runoff from the Site,
thereby preventing surface water and sediment contamination in nearby drainage ditches
and streams. Another objective of the remedy was to eliminate the sludge and soil as a
potential source of groundwater cont!3mination.
_ The ROD required the followiJg remediation levels for metals in the sludge and soil:
· ~-1~ lev~~,Pe sludge and soil must be reduced to 590 milligrams per liter (mg/I) of
-> _.,-.a<'"' to~;~~nlde In the non-TCLP extract and 30 mg/I of amenable cyanide; and
• Meials levels In the TCLP extract must not exceed the LDR levels below: .-.. -• ,.;-,--? -i .
Cadmium
Chromium
Lead
Nickel
Sliver
0.088 mg/I
5.2 mg/I
0.61 mg/I
0.32 mg/I
0.072 mg/I
2.2 RATIONALE FOR AMENDING THE REMEDY IN THE 1992 ROD
2.2.1 Results of the Treatablllty Study
As required in the 1992 ROD. a treatability study was conducted in 1994 to evaluate
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AREAS OF SLUDGE~tsoIL REQUIRING REMEDIATION ·, "t¥i""l . . . ..
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NO-RTH SUPERFUND ID: APR 02'98 11 :43 No.007 P.11 • • '
R'Zwrd er P22hl8o 6mandrotn1 MArnh 1996 _ &~onl-har!nalM_'.",..s'"
,>,«~--:fi-
,' ,// ~:tf\~ effect!~~ of alkaline chlorlnation in reducing the levels of cynanide in the sludge
"' and soil. ;;;ijni<fesults of this initial treatability study indicated that cyanide oxidation and
reduction 15y alkaline chlorination under the conditions tested was not sufficient to meet the
remediation levels in the 1992 ROD. Total cyanide concentrations ranged from 4,800
milligrams per killigram (mg/kg) to 5,500 mgll<g before treatment Following treatment, the
levGls of cyanide ranged from 1,400 mglkg to 1,900 mg/kg, well above the remediation
level of 590 mg/kg total cyanide established in the 1992 ROD. A EPA review led to the
following conclusion by EPA: "It is likely that the cyanide cannot be completely oxidized
because of the formation of iron and nickel complexes•.
J,
T
After reviewing ihe Treatablllty Study in 1994, EPA recommended that additional
treatablllty testing be conducted to evaluate alternative treatment technologies. Additional
testl ng of ali<aline chlorination was performed during the summer of 1994, The results
from this additional study indicated the remediation levels required in the 1992 ROD for
cyanide were achieved using alkaline chlorination; however, due to the apparent oxidation
of chromium during the alkaline chlorination process, the levels of chromium in the sludge
did not meet the remediation levels In the 1992 ROD.
__ -~ In 1995; after evaluating and screening a number of potential technologies,
-: -_,f·:ij,raghty 11<-~~recommended conducting further testlng of the sludge using hot alkaline
/.'-" )cfi1orlnat1q{i1;i;nd low temperature th,ermal desorption. The results of the 1995 study
lndlcated;'~!"6oth hot alkaline chlorination and low temperature thermal desorption could
be.used 16 successfully remediate cy~nide to reach the remediation levels required In the
1992 ROD. However, both treatment processes exhibit technological limltatlons which
may require additional treatability or pilot scale testing. These limitations may Inhibit full
scale implementation of the technology. The two technologies were summarized as
follows:
•
•
Hot alka,lioe chlorination required a high chemical dose and a moderately long
treatmr,mt time, and produces a significant amount of hexavalent chromium during
the cyanide oxidation process. Treatment of cyanide by hot alkaline chlorination
would require cyanide oxidation at an elevated pH, reduction of chromium at a low
pH, and subsequent neutralization and soil stabilization. -
Treatment of cyanide by low temperature thermal desorption also removed cyanide
to the remediation levels; however, some oxidation of chromium occurred.
2.2.2 Evaluation of the Supplemental Feasibility Study
Ba~Ei~the treatability studies conducted in 1994 and 1995, Geraghty & Miller ~~ ?~jjt' . V 6 •
C
NORTH SUPERFUND ID: APR 02'98 11:43 No.007 P.12 • '· •
,;,;~ .•.
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/-c 3 -•1ji:ei.,otronlos/Cv· -or Sho (r., ,, ,;·,-±2f: ' . I'• .
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conducted a Supplemental Feaslblllty Study (SFS) in 1996. The objectives of the SFS
were as follows:
•
•
•
supplement the initial Feasibility Study with a review and assessment of
alkaline chlorination and thermal desorption, as well as alternate treatment
technologies for cyanide and metals in the sludge and soil;
develop detailed cost estimates for the hot alkaline chlorination and thermal
desorption technologies retained In this assessment: and
recommend a specific treatment technology which can achieve the
· remediation levels required in the 1992 ROD for cyanide and metals.
3.0 OTHER ALTERNATIVES CONSIDERED IN THE 1992 ROD FOR THE SLUDGE
~ ANDSOIL
,s.t;~~ -~ /,-1--~ The l~~2 FeaSibility Study evaluated five remedial alternatives for addressing
-'lhe cont!\rolfi~ted sludge and s011 at the Site. The following paragraph provides a brief
_,,. · evaluationiof the four alternatives not selected In the 1992 ROD.
•' -" -►. .. .--,,. The first alternative Included a "No Action· alternative. The 1992 Feasibility
Study determined that the "No Actio'n" alternative would not be protective of human
health and the environment. Therefore, the "No Action" alternative was not acceptable
to EPA.
,
The second alternative involved the use of fencing, warning signs, deed
restrictions, and capping as a means of providing protection to human health and the
environment. Using institutional actions and capping the Site would reduce the mobility
of the sludge and soil, but would not reduce the toxicity or volume of the sludge and
soil. Leaving the sludge and soil on the Site would require Implementing deed
restrictions for future land use and maintaining the warning signs and fencing. The
long-term effectiveness of this alternative is questionable.
The third alternative would involve excavating and transporting the sludge and
_ soi~off•site fq!iJtreatment and disposal. While this remedy would effectively remove the • ;&%'1~affie and s9,j!~from the Site, the storage, transportation and disposal of the
/,:-;; --rclrntaminatoo1sfudge and soil would be subject to RCRA and DOT regulations.
,-.,. -,"' TJ~ alternative involved excavation and on-site treatment with vitrification
7
NORTH SUPERFUND ID: APR 02'98 11:44 No.007 P.13 • \ •
Mru:rbl998
and subsequent backfilling and capping. This alternative would be a permanent
remedy that would reduce the risks associated with the sludge and soil at the Site.
However, vitrification is a new innovative technology, and there is limited data
available to evaluate this technology's effectiveness.
4.0 COMPARISON OF THE SLUDGE AND SOIL REMEDY IN THE 1992 ROD
WITH THE MODIFIED REMEDY
The original remedy In the 1992 ROD required approximately 3,000 cubic yards
of contaminated sludge and soil to be excavated from the eleven sludge drying beds
and surrounding areas. Figure 2 shows the areas identified In the 1992 ROD requiring
remediation. Verification sampling would be performed during the excavation to ensure
that all areas of contamination have been removed for treatment. The 1992 ROD
~egulred the sludge and soil to be stockpiled, slurried, and transferred to a treatment
· "J?.Je~el whergftfilralkaline chlorination process would take place. A cleanup
.. /:;; ~]e'nficatiO!lj?l.trtwould be prepared during the design phase to ensure that the
appropri~W,tri:tifmber of samples are collected to prove that the Site has been
remediated~ "
cyanide and TCLP analysis would be performed during the treatment process to
ensure that the alkaline chlorination treatment process is achieving the remediation
levels established In the 1992 ROD.:' Following the alkaline chlorination process, the
sludge and soil would be stabilized with a chemical reagent suoh as Portland Cement.
The treated sludge and soil would then be backfilled into the excavated areas and
capped. For detailed descriptions of Alternative #4, refer to Section 8.5.2 of the 1992
Feasibility Study, as well as Section VIII B, page 82, and Section X, page 98, of the
1992 ROD.
The modified remedy requires treatment of 3,000 cubic yards of contaminated
sludge and soil. including 1,750 cubic yards of cynanide-lmpacted sludge requiring
cyanide treatment and subsequent metals stabilization, and 1.250 cubic yards of soil
requiring metals stabilization. The 1,750 cubic yards of contaminated sludge would be
excavated and transported to an approved off-site facility for treatment and disposal.
. ~he;ij ,250 cubip yards of contaminated soil would be stablllzed on-site, backfilled into
· \f:":.t~"e'fexcav~~]1lreas, covered with soil, and seeded with grass ..
/· ;I (~ c'i;ci?'
· 5.0 EV<~,.' ;l!JATION OF THE AMENDED REMEDY
" . . .
5.1 Overall Protection of Human Health and the Environment
8
ID: APR 02'98 11 :45 No.007 P.14 • •
ReoOrd bl Paculon &rmndmmt Mooch 1898 Jto elooitooioM'.;h•nrol Mostor SIie
The remedy in the 1992 ROD provided a permanent treatment thereby
eliminating the potential risks assooiated with tho dermal contact and ingestion of the
sludge and soil. The remedy would also eliminate the potential for the contaminants in
the sludgo and soil from migrating off-site via surface water runoff and adversely
impacting the nearby drainage ditches and streams.
Similar to the original remedy, the modified remedy would provide a permanent
treatment thereby eliminating the potential dermal contact and ingestion of the sludge
and soil. The modified remedy would also eliminate the potential for contaminants in
the soil from migrating off-site via surface water runoff and adversely Impacting-the
}l$larby dralna9e0ditches and streams.
",?::~~ <~-/,:_a 5;,2 Compli nee with ARARs <-'-r•:-,~l''.'i
Th~-ARARs governing the implementation of Alternative #4, as described in the
1992 Feasibility Study, would apply to the excavation, treatment, and disposal of the
sludge and soil, reclamation and capping of the excavated areas, and the monitoring
activities. The Land Disposal Restrictions (LDRs) (40 CFA Part 268] are not an ARAR
for the on•site treatment of sludge and soil as long as the excavated AGRA wastes are
not removed from the areas of concern during the remedial action. All appropriate
North Carolina Solld Waste Disposal Regulations [NCAC, Title 15A, Ch. 13B] identified
In the 1992 ROD would be an ARAR 'for this remedy. I
Excavating and transporting the sludge off-site for treatment and disposal would
trigger Department of Transportation regulations for the transportation of RCRA
hazardous waste [49 CFR Parts 107, 171-179], and RCRA Land Disposal Restrictions
(LDRs) because the sludge and soil ls characterized as FOOS and F019 RCRA
hazardous waste (40 CFR Part 268]. The off-site treatment and disposal facility would
be responsible for the appropriate RCRA permits as a Treatment. Storage. and
Disposal facility [40 CFR Part 262]. The Occupational Safety and Health Regulations
. (Q~llfA), and th~ North Carolina Solid Waste Disposal Regulations [NCAC, Title 15A,
.• "J~l,i13B], \'/~be an ARAR for this remedy.
/,-:J ( }(13 .Jt: ,/it'
5.3 Lo,!]jtilrm Effectiveness and Permanence
Treatabilily Studies were conducted in 1994 and 1995 to evaluate the
· effectiveness of the alkaline chlorination process in reducing the toxicity, mobility, and
volume of contaminants li1 the sludge and soil. The results indicated that alkaline
chlorination would not reduce the levels of cyanide in the sludge to meet the
remediation levels established in the 1992 ROD. Stabilization was not conducted on
9
' .: .::.:~
(,~ -i,/
NORTH SUPERFUNii¥' ID: APR 02'98 11:45 No.007 P.15
C
·•~·
• •
B0rord Pl QerJslqn AwndUJDP1 Mardl1Q98
Jm 8oo1ronlcs/Channol M8'1er Stt•
the sludge during the 1994 and 1005 Treatability Studies since the alkaline chlorination
treatment process was not successful.
The off-site treatment and disposal of the sludge would permanently and
effectively re.move the sludge from the JFD Electronics/Channel Master Site.
The contaminated soil would be stabilized on-site: the metals would be immobilized to
meet the remediation levels established in the 1992 ROD. Sampling and analyzing the
stabilized material for TCLP constituents would verify the effectiveness of the remedy. ·; ;ff~~, Re~u.ln of Toxicity, Mobility, or Volume -
/--;J ? ", ~"
' Th,i;994 and 1995 Treatabllity Studies indicated that the levels of cyanide In
---·1,
the sludgewere not reduced to the remediation levels established in the 1992 ROD.
Therefore, the alkaline chlorination technology proved to be Ineffective in reducing the
toxicity of the sludge. ,-
The vplume of hazardous waste would be reduced at the Site by excavating and
transporting the sludge off-site to a treatment and disposal facility. Stabilizing the
contaminated soil on-site would reduce Its toxicity and moblllty, However, the volume
of the sail would increase due to the addition of a chemical reagent such as Portland
Cement.
i 5.5 Short-term Effecllveness '
The Implementation of this alternative would involve potential risks to the nearby
community and remedial workers due to the potential direct contact and inhalation of
the contaminants in the sludge and soil, The 1994 and 1995 Trnatabitity Studies
indicated that an extremely large volume of reagent would be needed to complete the
, . ~line chlort~ation process on-site. The presence of large volumes of reagent on-site
.· • ~.~✓iwotfta also.p~?ent potential risks to workers and nearby residents. These studies also
/,-.a }lWci'icatecJJ!fJ.fhe on-site treatment process could involve unecessary risks due to the
potential;~cyanide gases being generated during the ~eatment process.
An implementation plan and health and safety plan would be prepared to
minimize any potential impacts to nearby residents or to remedial workers performing
the excavation, treatment, or disposal. Confirmatory sampling and analysis of the
· treated materials would be performed to ensure that the soil has been removed to meet
the remediation levels specified in the 1992 ROD .
.Potential risks to the remedial workers would be of concern in the event of direct
10
; -: •/, ,.
<;; ~ '·,~
~!.
; .. :.:~ !,~: _;c<
NORTH SUPERFUND ID: APR 02'98 11:46 No.007 P.16~tf -• •
R9wn:I at Onchlm AmepdrnnDI Mru:rb 18QB
JFD Efeclroolcs/Chennel Mm.tar $he
contact and inhalation exposure during implementation of the remedy. Potential risks
to the community would be of concern in the event of inhalation exposure due to
fugitive air emissions during implementation of the remedy. Potential risks to the
community would also be of concern during transportation of the sludge along public
roads and highways to the treatment and disposal facility. Confirmatory sampling and
t,~{!ts would be performed to ensure that all contaminated sludge was removed, and
, "'-!~Jfy th~:~eated soil meets the remediation levels established in the 1992 ROD.
_ __,_ ;,-;1 ,'5.6 lm;~entabllity _
The 1994 and 1995 Treatability Studies indicated"that the use of alkaline
chlorl nation for treating the sludge and soil on-site would not be technically feasible.
However, on-site treatment of the contaminated soit would be readily implementable.
The excavation and off-site treatment and disposal of the sludge would be
readily implemented with no significant operational or administrative dlfflcultles.
On-site treatment of the contaminated sol! would be readily Implementable.
Facllltles are avallabte with the necessary equipment and personnel to complete the
treatment process.
5.7 Cost
i The 1992 ROD estimated the total present worth cost to be $1,211,000.
However, based on the 1994 and 1995 Treatability Studies, the Supplemental
Feasibility Study estimated the total present worth cost to be
$5,048,677.
".;ff~ The·pfint worth total cost of excavating and transporting the sludge off-site for
/,-;J ,-"ireatmentandiclisposal. and stabilizing the soil on-site, is $2,582,385.
;~ -
5.8 State Acceptance ,
The State of North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR) concurred with the remedy selected in the 1992 ROD,
The NCDENR concurs with this modified remedy.
5.9 Community Acceptance
The community generally accepted the remedy in the 1992 ROD. See the
11
NORTH SUPERFUND ID: APR 02'98 11:46 No.007 P.17 • •
~dm1GeD11L__ _______ ...;.... ________ Mar"'mwlLU11Q08
JfD Elowonlca/Ch1a1nel Masl<lr SIio
Responsiveness Summary, which is APPENDIX B to the 1992 ROD.
The 30-day public comment period has not been held when this document was
drafted; however, the comment period will occur In April 1998. This section will be -~ ~~~ ~v;::.: : '"15_~1ed o~c~.public comments period occurs.
/,_,, '6.0 STA:f!l70RY DETERMINATIONS
"> ~~ -
The modified remedy satisties CERCLA Section 121; the remedy is protective of
human health and the environment, complies with ARARs, is cost effective, and utmzes
permanent solutions and alternative treatment technologies to the maximum extent
practicable. Preference for treatment as a principal element is satisfied by other
aspects of the overall remediation of the JFD Electronics/Channel Master Site.
7.0 RESPONSIVENESS SUMMARY
WIii have to wait until public comment period is complete.
-~lt -"-, ,,
) ,
12
' -: •c ;--;,;;
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NORTH SUPERFUND ID: APR 02'98 11:47 No.007 P.18
'•_-:}~\ ,'
7 -
·-,,." ''._;;:~·y .'·
• •
RAl!Ofd or ppgc1l>n Ameodomm JFO Elootronk:8/Charmel MB&ter SIio
Merd\1008
'"'rl' . APPENDIX A . . . :r ORIGINAL RECORD OF D.ECISION
' . )
' -
,,
. ;
,1
~ -~!}ff~
-·"--,
--~ --"~ '
:,--,-
I
•
November 28, 1995
Memorandum
TO:
FROM:
RE: Draft Explanation of Significant Difference
Remedial Design
Channel Master Site
Oxford, Gr:awille County
•
1 phoned Ken Mallary today to discuss the proposed ESD for this site. To expedite the
Remedial Action, Ken wants to change the ROD to performance-based design and wants to rule
out the pubicly owned treatment works (POTW) for the water discharge. I told Ken that we
agreed with the performance-based approach, however, we would like to continue to lobby the
City of Oxford for a POTW discharge. Ken agreed and asked that we contact the City of Oxford
and find out why they are opposed to having the discharge go to the POTW. I agree to contact
the City of Oxford.
I phoned Mr. Tommy Marrow, Town Manager for the City of Oxford. Mr. Marrow
indicated that the request for the Channel Master site was the sixth such request from cleanups to
discharge water to the Oxford water-treatment plant. Mr. Marrow has rejected all such requests.
He claims that the plant has limited capacity and that all the capacity needs to be used for
industrial use, which will increase the tax base for the town.
Another reason given by Mr. Marrow for not accepting the water is that the treatment
plant is already frequently out of compliance. According to Mr. Marrow, the additional water
from the Superfund Site v;ill only increase the number of fines that the 1;,r,ility is required to pay.
Mr. Marrow said that one reason the discharge from the plant is often out of compliance
is that the EPA requires the facility to treat metals. The facility, which was built in 1989, was
not designed to treat metals. Mr. Marrow said that he would prefer that the water be discharged
to the creek at the site rather than the water treatment plant.
cc: Jack Butler
-• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
A,:-LANTA, GEORGIA 30365
JUL o 9 ~
4WD-NSRB
Wf t~ffW~aJJ
JUL 15 1992
SUPERfllftlD SEtrmru Mr. Jack Butler
North Carolina Dept. of Environment,
Health, and Natural Resources
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
Subject: Responses to ROD Comments
JFD Electronics/Channel Master Site
Dear Mr. Butler:
EPA-Region IV appreciates the State's conditional concurrence with the Record of Decision (ROD) for the JFD Electronics/ Channel Master site located in Oxfo'rd, North Carolina. For the record, EPA would like to respond to the comments made by NCDEHNR-Superfund Section, as submitted in your letter to me dated June 30, 1992. The purpose of these responses is merely to reflect our telephone conversation made on July 9, 1992 with Curt Fehn. This letter, along with your June 30, 1992 letter, will be included as an appendix to the ROD. These letters should stand as offical documentation that EPA-Region IV and NCDEHNR-Superfund Section have agreed on the preferred alternatives at this point in time, based on the following conditions:
1)
2)
'
that Treatability Studies will be conducted on the chosen remedies to ensure that the cleanup levels can be met;
that clean fill will be placed into the excavated sludge pits to ensure that the treated sludge/soil will not be deposited less than four feet above the seasonally high water table, and that by doing so, the original grade of the area will be affected (without any lateral· expansion). We also agreed that a cap would be necessary on top of the affected area;
3) the treated sludge/soil will pass TCLP. As stated in the past, EPA's position is that the State's
policy of comparing extractable levels of contaminants to either its groundwater standards or ten times its groundwater standards_ is not enforceable and thus not an ARAR. However, we anticipate that, at this Site, the treated sludge/soil will probably contain extractable levels of contaminants less than ten times the NC
Groundwater Standards as specified in NCAC Title 15, Subchapter 2L, Section .0202;
Printed on Recycled Paper
-
-2-
4) that, in the future, the State may put in place,
persuant to State law (G.S. 130A-310.8), a deed
recordation to document the presence of an "inactive
hazardous substance or waste disposal site";
5) that the location requirements (NCAC Title 15A,
Chapter 13A, Section .0009 (c and r)) for the Site
regarding the location of any treatment units with
regard to a 100-year floodplain will be met. We
also agreed that the sludge bed area (or future
treatment/disposal area), to the best of our
knowledge, does not violate location requirements
with regard to its proximity to residential
dwellings, wells, or any other requirement; and
6) that the sludge/soil cleanup level for chromium (310
ppm for a child) is calculated for hexavalent
chromium, whereas the calculated cleanup level for
trivalent chromium is 59,500 ppm for a child.
Please contact me at [phone] if you have any questions
or comments regarding this matter.
Sincerely,
flttc~ Mttuir
McKenzie Mallary
Remedial Project Manager
cc: Curt Fehn
/1112, 'vf\Clc (3 UTL-ee..
NCDEIINR -supeRi::vtvD sec.
lfo I o Be1<1... ',.; l'<D , sui,e.1 s-o
j?AL£,i•g 1-1, NC .l.. 7 t,,0 ~-
... ..
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary 30 June 1992
William L. Meyer
Director
Mr. McKenzie Mallary
Remedial Project Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Draft Record of Decision
JFD Electronics/Channel Master
NCD 122 263 825
Oxford, Granville County, NC
Dear Mr. Mallary:
The North Carolina Superfund Section has received and reviewed the Draft Record
of Decision for the subject site. A copy of this document has also been forwarded to the
North Carolina Division of Environmental Management (DEM) for concurrent review.
Comments from DEM will be forwarded when they are received by our office. The North
Carolina Superfund Section concurs with the chosen remediation technologies conditioned
on the following requirements being met:
1.
2.
Treatability studies as discussed on page 100 of the ROD will be used during
the Remedial Design phase to ensure that the chosen soil remediation
technologies will achieve the cleanup goals.
Onsite disposal of treated soil must meet the requirements of the 'North
Carolina Solid Waste Disposal Regulations (NCAC Title 15A, Chapter 13B,
Section .0503). Specifically the treated soil may not be deposited less than
four feet above the seasonal high groundwater table. It is our understanding
that the treated soil/sludge will contain extractable levels of contaminants less
than ten times the NC Groundwater standards as specified in NCAC Title 15,
Subchapter 2L, Section .0202.
An E.qual Opportunity Affinn..--.tive Action Employer
Mr. Mallary
June 30, 1992
Page 2
-
3. The on-site disposal of treated soil/sludge or presence of any residual
contamination that presents an overall total risk greater than 10-6 will require
deed recordation/restriction to document the presence of residual
contamination and limit future use of property as specified in G.S. 130A-
310.8.
4. The minimum buffer requirements as set forth in North Carolina Location
Requirements for Hazardous Waste Facilities (NCAC Title 15A, Chapter
13A, Section .0009 [c and r]) must be met for any proposed on-site treatment
technology. Data must be presented to address the applicable risk posed
standards for the North Carolina Location Criteria in NCAC Title 15A,
Chapter 13A, Section .0009 ( c and r).
5. The proposed soil cleanup level of 310 ppm as specified in Table 19 of the
ROD should assume all of the chromium is trivalent, not hexavalent as
indicated in Table 19.
The North Carolina Superfund Section appreciated the opportunity to review this
document. If you have any questions please contact me at [phone].
JB/dk/19
cc: Curt Fehn
Sincerely,
Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
May 29, 1992
MEMORANDUM
TO: Perry Nelson, Chief
Groundwater Section
Division of Environmental Management
FROM: Jack Butler, Environmental Engineering Supervisor o-;/:}fJ'
Superfund Section /tT/'
RE: JFD Electronics/Channel Master
NCD 122 263 825
Oxford, Granville County
William L. Meyer
Director
EPA Is in the process of completing a Record of Decision (ROD) for the JFD
Electronics/Channel Master Superfund Site, a National Priority List site.
Attached is one copy of the Draft ROD for the subject site. It is requested that this
document be forwarded to the appropriate sections of DEM and comments be submitted
to the NC Superfund Section. The NC Superfund Section will be reviewing this document
and submitting comments to EPA Region IV in the near future. It is our desire to include
the views and permitting requirements of the Air Quality, Groundwater, and Water Quality
Sections of DEM.
If you or your staff have any questions, please call me at [phone].
JB/dk/16
Attachment