NCD980729602_19941001_Jadco-Hughes_FRBCERCLA ROD_Record of Decision 1990 - 1994-OCR

.. ,·\
INTRODUCTION ·
· 1· ~ :_ 1::. 1 • ''; :: ..
The United States Environmental Protection Agency (EPA), the
lead Agency for the Jadco Hughes Site (the Site), located in
North Belmont, North Carolina, in collaboration jo,'ith the_ State ,of
North Carolina's Department of Environmental Health & Natural
Resources (NCDEHNR), has found reason to make•significant changes
to the Record of Decision (ROD) for the Jadco Site. The change
is a result of. a request from the Jadco Hughes Steering Committee
to modify the manner in which the selected remedy.is evaluated.I
Upon thorough· review and evaluation of the Steering Committees,
request, the change was incorporated into-: the-' R-OD. ·_ . '
EPA has prepared this Explanation of ·Sig~ificant _Differenc_e
Document (ESD)·, in ac~ordai:J.ce with CERCLA· S 117(c) and NCP §,,
300.435(c)(2)(i) to provide the public with detail information_on
the changes ma'de to the ROD.· _The ESD·will 0 beccime a part 0£-tlie'.
Administrative Record -File (AR), located at the Belmont Branch·of
the Gaston County Library System. '.,'..,:_ _ .. ,_;,1. -, •• ,,,,:_
Site History and Enforcement Analysis
. . 1 The Site is a former solvent reclamation and waste storage
facility operated by C.A. Hughes, Inc. from 1971 to 1975 and
later lease-.: to Jadco, Inc. until operations we:re suspended ·and
consequently terminated in 1975. Aerial photography indicates
that the facility was active as early c.5 1969 ;· · During· its
operation, the Site reclaimed used waste paint-and ink-type
solvents. The facility also stored drummed materfa-l'consisting
of waste chemicals and sludges from· area indus'tries. ·
In response to numerous complaints by neighboring residents
and subsequent documentation of frequent spills, the· State of '
North Carolina ordered the Site to be closed in 197S. In
addition, the State ordered the facility to be cleaned, which
included the excavation of two in-ground solvent pits, and the
consolidation of contaminated surface soil in an onsite landfill
located in the southwest quadrant of the Site. In 1983, the
remaining.-large storage tanks, a mobile ta·nker, and residual
drums were :removed from the Site.
In 1983, the EPA initiated a Superfund site investigation.
This investigation analyzed surface water, _·sediment, soil, and
groundwater samples. The data.collected were evaluated using the
Hazard Ranking System (HRS). The resulting HRS score was 42.00
( .• Hazard Ranking Systl1 (HRS). The resulting HRb ·score was 42.00 and r~flected the potential for groundwater and surface water, contamination. As a result, the EPA finalized the Site's placement on the National Priorities List (NPL) in_ 1§86.
Subsequently, EPA negotiated with a number of the companies, or potentially responsible parties (PRPs) that had conducted.: business with Jadco, Inc. and C.A. Hughes, Inc. to perform the Remedial Investigation, and Feasibility Study (FS), or RI/FS. ,In September 1986, an Administrativ.e Order on Consent was agreed"· upon by EPA and the PRP. Steering Committee. .The Administrative Order outlined the terms· under which EPA would allow the PRP Steering Committee to c?nduct, the RI/FS.
_• ("-.... ,,j ~,I !.t . . The first. draft, RI. Report. w_i;iS s_ubmitted t_o. _the EPA in Decembe3: of 1989. _A fir:ial'. RI._ Report was approved by. EPA in August' of 1990.. The RI _idei).'i:'ifA,ed contaminat_ion .· pres_ent in· · , . s1;1rface wat7r, sed~€)_nt:,.,,,~o.~t; i;iI_ld groundrcit~r. The-principal! site contaminants include volatile organic compounds (VOCs), ... extractable organic comp9unds ,. polychlorinated biphenyls .(PCBs:) and metal_s. The Risk=~s~si&~tt;. • ( RA) cgl)._d_y.!=ted at: th~· Site :t .. !:. revealed the major risk. to~public_health and the.environment to: be as~o'.ciate.d' 'with ing~s;1:':io~'{?( i::~ntaminat~.4 g:r;oundw_ater .P.,~,,~ ·. i.•.
Description of the Selected Remedy
, ..
The remedy addresses groundwater. contamination, .;.,hich -.;j;;~{J,:~{!tY; '•;., constitutes the principal health threat remaining at the Sit·e, as well as the remaining.soil .contamination, which continues to be a source for groundwater contamination. Groundwater remediation:: will be accomplished by pumping and treating-contaminated groundwater. Treated gz::9,undwater will be discharged to a publicly-owned treatment.works (POTW). The discharge of contamination into surface.water will be-addressed by the diversion of the flow of.surface water and replacement of an onsite culvert. Soil treatment will be conducted in situwith'a soil vacuum extrad:ion iiyiiteni t'ollowed by soil flushing.
The majoi: components of the sel~ctedremedy include:
o Institutional Controls and/or Other Land Use Restrictions; ·
o Groundwater Monitoring
o Groundwater Recovery via Extraction Wells .. : o Groundwat_er Treatin_ent via Aeration and Carbon Filtration to Pre-Treatment _Standards;
o Discharge of Treated Ef_fluent to the Mt. Holly POTW; o Treatab,i_Lit;.y Stl\dies _to. Ensure, Compliance with POTW
2
0
0
0
0
•• ·• , • _:. '; .'.,, .. ,. I_ : .. • . •• •; , ••
EPA has also selected ·a c
1
oritingeI1cy ,alt~rnat.i,ve, .in the event.
that the POTW does riot agree. to acdej:it t_he discha~ge ..
The major components of the contingency remedy include:
0
0
0
0
0
0
0
0
0
! . Institutional Controls and/or Other Land Use
Restrictions;
Groundwater Monitoring .. _ ...
Groundwater Recovery via _'Extraction Wells;
Groundwater· Treatment' i'rivolvi'ric;(Pre.'.:treatment for metals
followed by Ultravio_ie•_t Oxi'diz'ation to Pre-Treatment
Standards; .. ,.. · ·· "·'
Surface Water Discha:r;'ge ·of T:ri3ated E.ffluent;
Treatabi·lity Studies' tp Ensure Compl'iarice wi_th Surface
Water Discharge!" c·riteri.~; ' . _ ..
Soil· Vapor Extraction"followed by Carbon Adsorption of
removed vapor; · · .· ... · ..
So'il Flushing by ·:introduction Uncontaminated· Water; ·and·
Review of Groundwater. Use Every Five Years'.
The above stated remedy was outlined in the_ ROJ:? _.i_s_llu~d
September 1990. The Record of Dec'ision· providei's';a:'detail ,:
description of each component' oJ _the remedy;. for the Site.
DESCRIPTION OF -SIGNIFICANT DIFFERENCE
The record of decision ·as originally written, required soil
cleanup goals be provided. ·Table 14 in .r~co:i:d. of decision ( ROD)
contained soil clean-up goals' for 13 of the 42 contaminants ,
listed in Table 8 of the 'ROD;;· The~ goals listed in· Table 14, were·.
designed to reduce the contaminants in the soils to a level that
would prohibit soil leachate from negatively impacting
groundwater. The ROD required that soil cleanup goals be
developed for the remaining contaminants (listed in Table 8 and
not listed in Table 14 of the ROD) during the pre-design work.
The soils would be cleaned to these levels, and then sampled to
verify that they met these predetermined soil clean-up goals.
The cha.nge to the remedy will require actual ·sampling of the
soil leachate, in the form of•'the ·recaptured flushing water .. The
results of .flushing water sample ari.aiyses will be compared to
groundwater remediation goals outlined in the ROD. At the point
3
\.\
• in which the sampling results of the soil, ... l~acl),_a_1=.~.i!!1~~-t--:the r remediatio':1 . goals a_s,. Pff~e1~e.~, ip,:2;',~b~-~-. 1 ~f; ?f ~ 1:!1~.,:!lO_I?)~;:t( giyen adequate:\ t J.Ine c:-to:.a·s sure"tha t the·' partitioning of c_ont~_inants from the soil ~nto. the f l:ifllling w~te:r;~_.i_.s,. no,. longer,,_CJCCll_!:ring) ·, the soil: will ~no·0 1ong~r"-pe !~?:~'s\~~j:~d:_::a .. sc,mrc.e;~qf. ui:iacc::eptable risk to human health'"and'·the·envirbnment ... It is crucial that the extraction system used to recapture the flushing water is adequately design·ed to assure _capture. _The specifics of the design,will -be address~d-•in···tne 'r.emedial design document' and subject to EPA and NCDEHNR approval before actual implementation.
The actual treatment components of the remedy will remain unchanged. . The soi:l' remediat::ton goals, listed in· Table 14 of the ROD, established for the protection of groundwater will. not be required for the soil leachate verification method. The· groundwater remediatio,ri 1gci'aJJ[1~tIJ .. replace and accomplish. the goal of the so·il• reiiie'di'ati!cin'.'•g'oals '.'during leachate verification and groundwater· tmoni to ring. "''.Tlie' \;invi:i:onmeii'tal . risk ~s.so_ciated with direct contact with.the.soils present on ,Site are within EPA' s acceptable risk 'rarige'. '•"Fcir' more' detailed explanation of the risks assoc-iated w.1th'1the· Site,' re.fer to· ,the Record of· Decision or the Risk Assessment.documents, both ·of which are ·-~•i'""•. ,! ' ..... located in the, Adniinistrative Record.·· The """nge,. though a significant one, merely modifies how the effectiveness of the remedy is(,being evaluateid•;_· .'!' · >··• _ •·.•.· . · · . : ~-.:. : . ' · ... '
Conclusion
Considering the changes·that have been made to the selected remedy, the EPA and NCDEHNR 'b'eJ!ieve that the rciinedy remains protective of human health and the environment, complies with federal and state requirements that.were identified as applicable or relevant and appropriate to this remedial action, which include the North Carolina Administrative Cod0, Title 15, Subchapter 2L . 0100 and' . 0200'; Classification and Water Quality Standards•·'Applicable to· the'~Gr·oundwaters of North Carolina. In addition, the revised reme'dy utilizes permanent solution and alternative treatment technologies to the maximum extent practicable for this Site.
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•
The preceeding Explanation of Significant Difference (ESD) is issued whenever there has been the necessity of making a change to the Record of Decision concerning the remedial alternative and subsequent actions concerning a Superfund site. The Agency is required by law to issued a notice to the public concerning any change(s) made and the reasons the changes were made. The changes made are described on page 3 and 4 of this ESD which was signed on August 12, 1994.
The Agency is currently finalizing the Remedial Design for the selected remedy. Within the next few months we will prepare and mail a Remedial Design Fact Sheet providing details of the design. We will also be conducting a public meeting to go over this information and respond to citizen questions/ concerns. A notice will appear in the local newspaper announcing the meeting date as well as being announced in the fact sheet that will be mailed to citizens on the Site's mailing list.
In the meantime, if you have any questions concerning the action taken by this ESD or other questions concerning the Site, please feel free to contact:
Michael Townsend, Remedial Project Manager
Diane Barrett, Community Relations Coordinator
U.S. Environmental Protection Agency, Region 4
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, GA 30365
Phone: [phone], ext. 4108 or 4111
Copies of documents produced during the Superfund process including the Record of Decision are housed in the information repository located at:
Gaston County Public Library
Belmont Branch
111 Central Avenue
Belmont, North Carolina 28012
•
U.S. Envlronmenta, i>rotecUon Agency
345 CourUand Street, N.E.
North Superlund Remedial Branch
Diane Barrett, Community Relations Coore!.
Michael Townsend, Rem:j;;;1 Project Manager Atlanta, Georgia ~0365
Rtgion 4
Official Business
Penalty for Private Use $300
r--------
s/ F JACK BUTLER, CHIEF
SPECIAL PROJECTS BRANCH
NC DEPT ■ OF ENVIRONMENT,
NATURAL RESOURCES
JAC00013
HEALTH f.
1 p. □• BOX 27687
1 RALEIGH NC 27611-7687 ,, -----------___ __/
1111 1111 I ,,I, II ,,,I ,11,,1, ,l,l,, ,III, ,,I
.\' .
'
State of North ~lino
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr .. Governor
Jonathan B. Howes, Secretary
• NA
DEHNR.
William L. Meyer, Director July 14, 1994
Mr. Michael Townsend
Remedial Project Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: State Concurrence with the
Explanation of Significant Difference (ESD)
Jadco-Hughes
NCD 980 729 602
Belmont, Gaston County, NC
Dear Mr. Townsend:
The State of North Carolina has reviewed the Draft Explanation
of Significant Difference (ESD) to the Record of Decision (ROD) for
the Jadco Hughes NPL Site and concurs with the significant changes,
subject to the following conditions.
1. The ESD assumes that the soil leachate and groundwater
below the landfill area will achieve the groundwater
remediation goals established in Table 13 of the ROD. If
sampling results of the soil leachate do not meet the
groundwater remediation goals, a technical
impracticability waver from the NC Groundwater standards
cannot be provided for groundwater in the area of the
landfill until soil contaminant concentrations· are
verified to be at levels which are protective of
groundwater. This requirement is based on the NCAC Title
15A, Subchapter 2L, Section .0106.
2. State concurrence on this Draft ESD to the selected
remedy for the site is based solely on the information
contained in the Draft ESD dated July 13, 1994. Should
the State receive new or additional information which
significantly affects the conclusions contained in the
ESD, it may modify or withdraw this concurrence with
written notice to.EPA Region IV.
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Attirmctive Action Employer 50% recycled/ 10% post-consumer paper
Mr. Townsend
7-14-94
Page 2
•
3. State concurrence on this ESD 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, comment and make independent assessment of all future work relating to this site.
4. 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 opport1.Jnity to comment on the Draft ESD for the subject site, and we look forward to working with EPA on the final remedy.
Attachment
Sincerely,
Jack Butler, PE
Remediation Branch Head
Superfund Section
cc: Curt Fehn, Remedial Branch Section Chief
Mike Kelly, Deputy Division Director
Randy McElveen, NC Superfund Section
f 07/13/94 09:35 EP:'.i REG! Del PRCIGRRMS
'~• ,.,,.•~•' """"' M ,,-~"/
FAX TRANSMITTAL
INTRODUCTION
The United States Environmental Prete tion Agancy (EPA), ths
lead Agency for .the Jadco Hughes Site (the Site) 1 locatod in ·
North Belmont, North Carolina, in collabor tion with the State of
North Co.rolino. '., Departmeont; of Env1ronmen1:q.1 Health & Natural
Resources (NCDEHNR), has found reason to make significant changes
to the Record of Decision (ROD) for the Ja4co Sita. The change
i" a result of a requeat from the Jadoo Hughes Steering Conunittee
to modify tho mo.nner in which the selected remedy is evaluated,
Upon thorough review and evaluation of the Steering conunittees
request, the change was incorporated into he ROD.
BPA has prepared thie EKpl11notion of ignificant Difference
.Document (ESD), ln occord11nce with Cl5RCLA 117(0) and NCP S
300,435(c)(2)(i) to provide the public wit datail information on
the changes made to the ROD. The ESO will become a part of the
Administrative Record ~ile (AR), looatod a tho Belmont aranch of
tho Gaeton Cou:nty Libr,u:y Syi,tern, ·
.S,:i,.tl\l B:istory and Knforcement Analysis
The Site•is o. :Corm"r solvent reclamat
facility operated by c.A, Hughes, Inc. fro
later leased to Jadco, Inc. until operatio
consequent..ly term:l.nated in 1975. .Aerial p
that tho £0.cility woe active o~ early aa 1
oper .. tion1 the Site reclaimed used. waste p
solvents. The facility also stored drumme
waste chemicals Bnd sludges from area indu
on and waste storage
1971 to 1975 and
s were suspended and
oto9raphy indioatos
69, Durin\j itB
int and ink-type
material consisting
tries.
In reopon"" to uumei:outi uomplaints.by neighboring raeictents
and Bubsequent documentation of frequent a ills, the State of
North Carolina ordered the SJ.te to be cloa din 1975. In
addH:3.on, th,. State ordered tha facility-t be cleo.ned, which
inoludod the e><oavo.tion of two io-9round s lvent pits, and the
con~olidatlon of contaminated surface soil in an onsite landfill
located in the southwest quadrant of the s te. In 1983, the
remaining large storage tanks, a mobila talker, and roaidual
drums were removed from the Site,
In 1983 1 the EPA initiated a Superfun~ site investigation.
Thie investigation analyzed surface water, 1ssdiment, soil, and
c;iroundwatar samples. The data collooted w~e evaluated using the
Hazard Ranking Sy.,tem (HRS), The resulting HRS score was 42,00
07/J.3/94 09:37 EPR REG!Ot-1 JU WelSTE MGT PROGRRMS 002
and reflected the potential for groundwate
contrunination. As a result, the EPA tinal
placement on the Natlonttl Priorities List
Subsequently, EPA negotiated With an
or potontially responsible parties (PRPB)
business with Jadco, Xnc. and C.A. Hughes,
Remedial Investigation and Feasibility Stu
September 1996 1 an Administrative Order·on
upon by EPA and.the PRP Steering Committee
Order outlined the terms under which BPA w
Steering Comn1itt00 to conduct the RI/FS.
The first draft RI Report was subrnitt
December of 1999, A final RI Report was a
August 0£ 1990. ·1·he RI ident:ltied contami
surface wator1 aedimont1 soil and groundwa
site contaminants include volatile organic
extractable organic compounds, ploychlorin
and metals. The Risk Assessment (RA) cond
revealed the major risk to public health a
be o.ooociated with lngeljtion o( oontaminat
Description of the Selected Remegy
The remedy addresses groundwater cont
conatituteB tho principal health threat re
well as the remaini.ng soil contamination,
source for groundwater contamination. Gro
will be accomplished by pumping and treati
groundwater. Treated groundwater will be
publicly-owned treatment worka (PO:rw), Th
contaminatJon into surface water will be a
diversion of the flow of surface water and
on.site culvert. Soil treatment will be co
soil vacuum extract.Lon system followed by
The major components of the aelected remed
•
and surface water
zed the Site's
NFL) in 1,86.
er or the companies,
hat had conducted
Inc. to perform the
y (FS1, or RI/FS. In
Consent was agreed
The Administrative
uJ.d allow the PRP
ct to the EPA in
proved by EPA in
ation present in
er, The principal
compounds (VOCe)1 ted biphenyls (PCnsJ
cted at the Site
d the environment to
ct groundwater.
ination, which
aining at the Site, ae
hich continues to be a
ndwater remediation
g contaminated
ischargad to a
ct:Lscharge of
drosaed by the
replacement of an
ducted in situ with a
oil flushing.
include,
0 Institutional Controls and/or Other Land Use
Restrictions;
0
0
0
0
0
Groundwater Monitoring
Groundwater Recovery vio. Extraction Wells;
Ground.ri,ter Treatment via Aeration nd Carbon Filtrlltion
to Pre-Treatment Standards;
Dischar9e of Treated Effluent to th Mt. Holly POTW;
Treatability Studies to Ensure comp iance with POTW
Pro-treatment Standarde I·
2
.. 07/13/94 09:37 • EPA REG!Oi-1 IV. MGT PROGRRMS 003
o Backup Discharge Plan;
o soil vapor Extraction foll.owed by ax:bon Adsorption of
removed vapor;
o So.i.l Flushing by introduction unool'\taminnte,d water; and
o Review of Groundwater Use Every Fiv.e Years.
El'.11. hae o1oo eelect;eu a con"t;.1.ngency a11Irnative, .tn the event
that the POTW does not agree 1;0 accept thjdischarge.
The major components of the contingency r edy 1nclude1
o Institutional controls and/or Otha Land use
neetrictione; d o Groundwater Monitoring
o Groundwater Recovery via Extractio Wells;
o Groundwater Treatment involving Pre
1
-treatment for metals
followed by Ultraviolet Oxidizatio to Pre-Treatment
Standards;
o Surface Water Discharge of Treated ,ffluent;
o Treatability Studies to Ensure lance wi.th surface
Water Discharge Criteria;
o Soil Vapor Extraction followed rbon Adsorption of
removed vapor;
o So.il. Fl.uahing by Introduction uncon <11ninat1;>d water; and
o Review of Groundwater Use Every Fiv Yeara,
The above stated remedy was outlined in the ROD issued
September 1990. The Record o! Decision pr vides a ctetail
desc:r.l.pt.lon of each component of the remed for the Site,
DESCRlFTION OF SIGNIFICANT OIFFEMNCE
'I'he record of deciaion aa ori9innl.ly,-wr tten, required soil
oleanup goals be provided. Table 14 iI{~~it ord of decision (ROD)
contained soil clean-up goals for 13 of~~t( 42 contaminants
listed in '.l'able 8 oi the ROD, The goals 1 sted in Table 14, were
designed to reduce the contaminants in the soils to a level that
would prohibit soil leachate from negative y impacting
groundwBter. The ROD required that soil c e11nup goals be
developed fox the remaining contlllllinantR ( 1 isted _,in •rnble 8 and
not listed In Table 14 of the ROD) during he pre-design woxk,
The soils would be cleaned to these levels, and then sampled to
verify that they met the13e prede-cermineCl s il clean-up goals,.
The change to the remedy will require a tual sampling of the
soil leachate, in the form of the recaptur d flushing water. The
re,mlta of fluishing w11ter sample analyses 111 be compared to
groundwater ren1adiation goali:, outlined in he ROD, At the point
3
1'19:38 EPA REG I ON I U • MGT PRIJGRl=IMS 004
in which the sampling results of the soil
remediation goals as presented in Table 13
adequate ti.me to assure that the partition
from the eoil into the £lushing water is n
the tsoil will"no longer be considered a so
risk to human, health imd the environment,
extraction system used to recapture the fl
adequately designed to assure capture, Th
do.,;l_gn will bo 0.ddre.,oed in the ;L"emedittl <.l.
subject to EPA and NCDEHNR approval before
Tho actual treatment components of the
unchanged, The 1:1oil remediation goals, 11
ROD, established for the protection of gro
required for the soil leachate verificatio
groundwater remediation goals will replace
goal 0£ the ooil remediation goali, du,;in11
and g,;oundwater monitoring, The environme
with direct contact with the soils present
EPA's acceptable risk range. For more det
the ri.,ks aeeooiated with the Site, refer
Decieio11 o,: the ,U.,k Assessment <.l.ocuments,
located in the Administrative Record; The
signi£icant one, merely modifies how thee
r.emedy is being evaluated,
Conoiderin9 the .ohangee that have been
remedy, the EPA and NCDEHNR believe that t
protective o[ human health and the enviro
federal and state requirements that were i
or relevant and appropriate to this ramedi
include the North C11roline1 Administrat,1.ve
Subchapter 2L ,0100 and ,0200; Classificat
Standards Applicable to the Groundwaters o
addition, the revised remedy utili~es perm
alternative trentmont technologie3 to the
practicable for this Site.
eachate meet the
of the ROD, ( givQn.
ng of contaminants
longer occurring).,
roe of uno.CC'<lptlibl,e
It is crucial that the
shing water is
opecifica of the
sign ctocwnent and
actual implementation.
emedy will .:emain
tea 1n TaDle 14 of the
nctwater will not be
mathod, 'l.'he
and accomplish the
ee1chate veri!1cat1on
tal risk associated
on Site are within
iled explanation of
o the Record of
Dot.h of which are
change, though a
fectiveneaa of the
ade to the aelected
e remedy remains
ent, oomplies with
entified as applicable
l action, which
ode, Title 15 1 on and water Quality
North Carolina. J.n
nent solution and
ax1mum ~><tent
State of North .)lino
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
June 21, 1994
TO:
FROM:
RE:
Arthur Mouberry, Chief
Groundwater Section
Division of Environmental Management (DEM)
Randy McElveen
Environmental Engineer
NC Superfund Section
Draft Explanation of Significant Difference
Jadco-Hughes NPL Site
NCD 980 729 602
Belmont, Gaston County, North Carolina
EPA is in the process of completing a Draft Explanation of
Significant Difference (ESD) to the record of decision (ROD) for
the Jadco-Hughes Superfund Site, a National Priority List site.
Attached is one copy of the Draft Explanation of Significant
Difference for the subject site. This ESD report was prepared by
the US EPA, Region IV. It is requested that these documents 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 on or before May 18, 1994. 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 do not
hesitate to call us at [phone].
Attachment
cc/ Jack Butler, NC Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
State of North ~olina
Department of Environment,
Health and Natural Resources CO PY
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
June 20, 1994
Mr. Michael Townsend
Remedial Project Manager
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Draft Explanation of significant Difference
Jadco-Hughes NFL Site
NCD 980 729 602
Belmont, Gaston County, NC
Dear Mr. Townsend:
The Draft Explanation of Significant Difference (ESD) for the
Jadco-Hughes NPL Site located in Belmont, North Carolina has been
received and reviewed by the North Carolina Superfund Section.
This document has also been forwarded to the NC DEM for concurrent
review. Their comments will be forwarded when available. The
following comments are offered by the North Carolina superfund
Section.
The following comments are from the Description of Significant
Difference Section:
1. The first paragraph should be re-worded as recommended
below.
Table 14 in record of decision {ROD) contained soil
clean-up goals for 13 of the 42 contaminants listed in
Table 8 of the ROD. The goals listed in Table 14, were
designed to reduce the contaminants in the soils to a
level that would prohibit soil leachate from negatively
impacting groundwater. The ROD required that soil clean~'
up goals be developed for the remaining contaminants
(listed in Table 8 and not listed in Table 14 of the ROD)
during the pre-design work. The soils would be cleaned
to these levels, and then sampled to verify that they met
these predetermined soil clean-up goals.
2. The second sentence of the second paragraph should read
"The results of flushing water sample analyses will be
compared . . . "
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post•consumer paper
•
Mr. Townsend
6-22-94
Page 2
3. Re-word the second paragraph as follows.". . . groundwater
remediation goals as presented in Table 13 of the ROD."
4. Groundwater remediation goals should be re-stated in the
third sentence of the second paragraph for clarity.
5. The second paragraph assumes that sample analytical
results of the soil leachate will meet the remediation
goals. The state has stated previously that language
should be included in this ESD which addresses the
possibility that groundwater remediation goals are not
met within a reasonable time period. Under the leachate
monitoring verification plan it is critical that a
contingency treatment technology be included in the ESD.
It must also be stated that a technical impracticability
(TI) waver cannot be provided for the groundwater in the
area of the landfill using the present verification
technology. One of the State concerns at this site is
that the leachate and groundwater in the area of the
landfill will not achieve the groundwater standards. If
this occurs the soils remedy must be reevaluated. It
should be clarified that a TI waver is not appropriate
until a post treatment soil sampling and analysis plan
has been implemented and the results indicate that the
contaminant concentrations in and below the landfill are
at levels which are protective of the groundwater.
6, The second sentence of the paragraph at the top of the
last page should be re-worded as recommended below. "The
soil remediation goals, listed in Table 14 of the ROD,
established for the protection of groundwater will not be
required for the soil leachate verification method." The
following sentence should be re-worded as recommended
below. "The groundwater remediation goals will replace
and accomplish the goal of the soil remediation goals
during leachate verification and groundwater monitoring."
If you have any questions or comments, please do not hesitate
to contact us at [phone].
Sincerely~
'-10 ~. '\Mc
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4W-NSRB
Mr. Randy McElveen
Environmental Engineer
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
January 21, 1994
N.C. Department of Environmental,
Health & Natural Resources
401 Oberlin Road
RECEIVED \I
JAN 2 6 1994
SUPERFUND SECTION I
Raleigh, NC 27605 ::C.. i-6---=: ' . 1-rt?
CJ~r::-tA-0:he&-· ,,.,.1:/J
SUBJ: The PRP's Proposed Modifications to the::::_Record-of-Decis·ionl)
The proposal that EPA is presently evaluating from the
Potentially Responsible Parties, does not change the remedy
outlined in the ROD in any way. The proposal is requesting that
EPA consider a different method of evaluating the performance of
the remedy.
Instead of using modeling to determine what soil remediation
goals are protective of the groundwater, the proposal seeks to
evaluate the groundwater directly to determine if the remedy
selected has been protective of the groundwater. Given the
remedy selected for this Site, which use soil flushing to remove
all residual contamination left by the soil vapor extraction
system, makes this an ideal solution to our present dilemma with
the calculation of remediation goals. The water used in the
soil flushing process must be captured by the presently proposed
pump and treat system. By evaluating the influent of the
treatment system we will be able to directly determine what
impact the soil is having on the groundwater. Modeling is an
invaluable tool in our industry and as you are aware we regard
tha ~sa of ruvdeling highly, but in a case ouch as this, an
opportunity_ to directly monitor the performance of the selected
treatment should not be foregone.
The PRP'S must still provide verification that the soils are
well within health base standards, and propose a method to
accurately monitor and evaluate the influent of the groundwater
treatment system. Keep in mind that if the proposal is not
acceptable to you, we will be left with the dilemma of
determining which models or methods to use to calculate soil
remediation goals to protect groundwater.
Printed on Recycled Paper
•
2
I truly appreciate you taking a second look a the PRP's
proposal, ,I believe-the proposal is the better way to proceed.
If you have any additional questions don't hesitate to contact
me.
'/11:t/J;;
Michael F. Townsend
Remedial Project Manager
\ -,
4W-NSRB
B!iffis.i, w r ui "-11 : s2 EPH PEG I IJ1,, I lJ GI.O.STE MGT FF:CGF:Hl'l':c,
I • l
I
I
UNITED STATES ENVIRONMENTAL fROT, CTION AGENCY
REGION IV
:,,45 COURTLAND STREE1, N.E,
ATLANTA, GE.ORGIA 30305
January
801
I •r~~I\
Mr. Randy McElveen . ....fiotc \.\f¥t:L ,i-M.JN!>j;NO
Environmental Engineer Pi~;" _ 711
N. C. Department' of Env ironmantal, J:,,,,ts, ,~D~tt,,U;:,.__ ___ -k"2.~:L.O...!... ___ _
~~~l~~e;l~~t~~!~ Resources "";%,{'J,,,;iZF-3 ~ '°"''' GJ:Nr.Rfll. St;:11\IIGl:.S Allt;'l1~1$TRf.ii'o'N
Raleigh, NC 21ios · . /
SUBJ I Th~9; -~~ Modi f ica_t_i_o_n_5_t_o_li-t_h_e_O,..R--e-_c_"()_r_a ___ o_f_-o_e_c_i .. _~--i-:o"':;--"""'--
The proposal that EPA is pre6ently evaluating from the
Potentially Responsible Parties, does not dhange the remedy
outlined in the ROD in any way. The propos'al is requesting that
EPA consider a different method of evaluat~ng the performance of
the remedy, . . )
Instead of using modeling to determin~ what soil remediation
goals are protective of the groundwater, the proposal seeks to
evaluate the groundwater directly to deternhne if the remedy
selected has been protective of the groundwater. Given the
remedy selected for this Site, which use sdil flushing to remove
a11 resiCiuai contamination left by the soi~ vapor extraction
system, makes this an ideal solu::ion to ou:d present dilemma with
the calculation of remediation goals. Th~ wa\.er used in the
soil flushing process must be captured by the presently proposed
pump and treat system. By evaluatir..g the i!,nfluent of the
treatment system we will be able to directl;y determine what
impact the soil is having on the gr0undwater. Modeling is an
invaluable tool in our industry and as you !are aware we regard
the use of modeling highly, but in a case ~uch as this, an
opportunity to directly monitor the performance of the selected
treatment ahould not be [ore:gone. I
!
The PRP'S must still provide verification that the soils are
well within health base standards, and propose a method to
accurately monitor and evaluate the influent of the groundwater
treatment system, Keep in mind that if th~ propoaal is not
acceptable to you, we will be left with th1· dilemma of
determining which models or methods to use to calculate soil
remediation goals to protect groundwater.
!
I
• I
2
I truly appreciate you taking 11 second· ook a the PRP's
proposal, .I believe the proposal is the bett~r ~ay to proceed.
If you have any additional questions don't hrsitate to contact me.
'i?Tit ._-17
Michael F. To· send \
!\.'-'111"'.Jlal.. r.i.vJ" ·L HaHCl\j""-
MEMORANDUM
TO:
FROM:
December 1, 1993
File
Randy McElveen
Environmental Engineer
NC Superfund
•
RE: ROD Amendment/ESD and Intermediate Design for Jadco
.Hughes NPL Site
This office was contacted on the above date by Michael
Townsend, EPA RPM for the subject Site. Mr. Townsend stated that
the PRPs for the Site would like to use groundwater monitoring of
the subject site as the remedial verification for the soils at the
site as opposed to testing soil columns as proposed in the ROD.
The technology involves soil flushing and recapturing the water
contaminated by flushing by a series of extraction wells which can
be shown through modeling will recapture all flush water. If
Groundwater Quality Standards are not met, the groundwater
extraction system will continue to capture and treat the
contaminant plume until the groundwater standards are met. Mr.
Townsend also stated that the preliminary design has already been
turned around by EPA without review by the State. The Draft
Intermediate Design is underway at this time and will be forwarded
to this office when completed.
cc: Jack Butler, NC Superfund
• • UNITi::D ST ATES ENVIRONMENT AL PROTECTION AGENCY
4WD-NSRB
David Pond
W.K. Dickson
1924 Cleveland Ave.
REGION IV
34S COURTLAND STREE:7. N.E.
ATLANTA. GEORGiA 30365
Charlotte, North Carolina 28203
Re: JADCO-Hughes Site
North Belmont, North Carolina
Dear Mr. Pond:
·RECt.lVED
MAY 2 6 i9:Ji
SUPERFUNO SECTION
The Record of Decision (ROD), the Remedial Investigation (RI)
Report and the EPA guidance on CERCLA Site Discharges to POTWs are
included for your information. Please request whatever data or
historical information that you need. I will be glad to submit
copies to_ you and to the City of Mt. Holly. The North Belmont
Branch Library of the Gaston County Library System maintains an
Information Repository for the JADCO-Hughes site. A copy of the
Site Administrative Record is available for public reference.
Please contact me if you have any additional questions. I can be
reached at 404/347-7791.
;
Si~perely, /,
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,' -~ (
Barbara H; Benoy ,_;
Remedial Project Manager
Waste Management Division
Enclosure
cc: Curt Fehn, NCRS /
Reuben Bussey, ORC /
Bruce Nicholson, NCDEHNR
Eddie Nichols, City of Mt. Holly
Printed on Recycled P.1per
LACY H. THORNBUHG
ATfORNEY GENEHAL
•
State of North Carolina
Department of Justice
P.O. BOX fi29
RALEIGH
27602·0629
--MEMORANDUM--
TO:
FROM:
DATE:
RE:
Lee Crosby
Suzy Moser
Rob Gelblum R/;
January 23, 1992
JADCO/Hughes Superfund Site
This is simply to apprise you that yesterday I spoke with the
EPA Region IV attorney in this matter. He indicated that Region IV
expects (though the litigation will be handled by a Department of
Justice attorney out of D.C.) a response cost recovery suit for
approximately $115,000 to be filed on or about January 28, 1992.
The suit will be against "recalcitrant" PRPs. To the others, who
have offered the remainder of the $485,000 or so in costs, the
federal government will provide "covenants not to sue." Clearly,
it would be desirable to provide EPA our cost recovery package as
soon as possible. Whenever you get back to me on your affidavit,
Suzy, we can finalize it and then, assuming everything else is in
order, ship out the package.
RB/dw
:epmemo-6
LACY H. THORNBUnG
ATTORNEY GENERAL
To:
From:
Re:
Date:
• •
State of North Carolina
Department of Justice
Lee Crosby
Jill Hickey~-
Jadco Hughes
October 4, 1991
P.O. BOX629
RALEIGH
27602-0629
MEMORANDUM
The PRP's at the Jadco Hughes NPL site declined to enter
into the ~ohsent Decree with EPA which we were negotiating last
February. --instead EPA issued a CERCLA § 106 order requiring the
PRPs to clean up the site. The PRPs are currently preparing the
remedial design (RD) for this site.
Steve Quigley with CRA has been hired to perform the RD. In
the course of the preparation of the RD, several questions have
arisen pertaining to background groundwater levels. According to
Steve, EPA has told the RPRs that the State will have the final
word on what constitutes background at this site.
Steve has requested that the appropriate State
representatives meet with him, Jimmy Kirkland (attorney), and
several of the PRPs who are dealing with technical issues at the
site. This group wants to reaffirm the outcome of our earlier
meeting in which Perry Nelson indicated that the groundwater
section would consider a petition by the PRPs to terminate pump
and treat after they demonstrated that they had reached the
asymptotic point on the treatment curve. The major issues are as
follows:
a. What is background at this site? Presently, there is
one monitoring well for measuring background. Is this
sufficient? If more are necessary, how many are needed and where
should they be located? The PRPs apparently believe that
groundwater in the surrounding area is contaminated by industrial
activity unrelated to the Jadco Hughes site, and they want some
degree of assurance that they will not be responsible for
remediating the contamination caused by other sites.
b. Another nearby site, the North Belmont site, has been
• •
the subject of considerable EPA activity. It is a dry cleaning
operation and the groundwater is contaminated with chlorinated
solvents. It is possible, although Steve is not sure how
possible, that this site might impact on the Jadco site. I do
not know what the precise questions will be, but the PRPs want
the assurance that they will not be responsible for cleaning up
the contamination caused by this other site.
c. Is there a proper methodology for taking samples? EPA
apparently is concerned that the PRPs may be measuring sediments
rather than groundwater in their current monitoring wells.
d. The PRPs are seeking to discharge treated wastes to the
POTW. Is the State involved at all in this process?
,
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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
17 June 1991
MEMORANDUM
TO: Bill Meyer, Director 6(JII,
Division of Solid Waste Management
FROM: Lee Crosby, Chief / , J
Superfund Section p ·
RE: Jadco Hughes
Gaston County
William L. Meyer
Director
Barbara Benoy, Project Manager, called to notify us that negotiations with the
responsible parties had failed for the Jadco Hughes NPL remedial action. EPA will be
issuing an unilateral order today. _We will be receiving a copy; no action is required.
LC/acr
• •
UNITED STATES ENVIRQNMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
JUN 1 7 1991
4WD-NSRB
Lee H. Crosby
North CarOlina Department of Environment,
Health and Natural Resources
Division of solid Waste Management
401 Oberlin Road
Raleigh, North Carolina 27605
RE: Jadco-Hughes Superfund site
North Belmont, North Carolina
Dear Ms. Crosby:
On May 30, 1991, the U.S. Environmental Protection Agency (EPA)
and the steering committee of potentially responsible parties
for the above-referenced site concluded remedial action consent
decree negotiations. These negotiations were conducted pursuant·
to the special notice procedures of section 122(e) of the
comprehensive Envfronm6I'ital Response, Compensation and 'Liability
Act (CERCLA) as amended. We were unable to reach final
agreement as to· certain key provisio_ps of the consent decree.
EPA has·, therefore, determined that a Unilateral Administrative
Order will' be issued 'against the owners of the site and parties
who caused hazardOus substances to be treated,-stored or
disposed_of at the site, or to be transported to the site for
such purposes. The Order requiring Remedial Design and Remedial
Action as specified_ in the Record of Decision executed by the
Regional Administrator on September 27., 1990, will be issued -on
June 17, 1991.
This letter constitutes notice to the state of North Carolina,
as provided in section 106(a) of CERCLA, of this Agency's
de~ermination to'isslle a Unilateral Administrative Order for
Remedial Action at the Jadco-Hughes superfund site.
f:Don Guinyard
Director
Waste Management Division
Printed on Recycled Paper
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,vironnvJn\QI P~otoctio:-i
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(l,;~~io-n IV
O!!ioo of r~ublic.A!lairs
Jt.5 Cooriland St. N(;.
A\lilnt.a, Cco:9i;:i_ 30305
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Tt:<1r1,;:.;:.1:c
-~EPA Environmental News [phone]
EPA SELECTS REMEDY FOR CLEANUP OF THE JADCO-HUGHES SUPERFUND SITE
IN_NORTH BELMONT, NC
The U.S. Envirorunen·tal Protection Agency
.announced today that the Record of Decision (ROD) selecting the
cleanup remedy for contamination remaining at .t·he Jadco-Hughes
Super.fund si.t.e in North Belmont, NC, has been signed. .
. . 'J;"l)e. iem<3dy consis,ts of extraction,· treatment and ·disposal of
groundwater and the·qonstruction of a soil·vapor extraction and soil
£1.ushing_ system to remove contaminants. Contamination in soils will
be treated until cleanup criteria are met. PCB-contaminated .soil is
currently being removed from.one area of the site. <rhe soil will be
disposed of off-site. cleanup costs are estimated at $4.8 m:!:llion
dollars. · ·
The ROD:ls available for public review at.the Gaston county
Public Library, 111 Central Avenue, Belmont, NC,
The site, located:in.an unincorporated area of North Belmont, NC,
is contaminated by organic compounds, polychlorinated· biphenyls
(PCBs), and metals. The.six acre site is a former solvent
reclo.mation and waste storage facility, operated by C. A, aughes,
Inc. from 1971 to 1975, that.was later leased to Jadoo, Inc., until
the State6£ North Carolina ordered operations to cease in.1975. The
site was placed on EPA'SNational Priorities List of hazardous waste
Dites in 1986.
-o-:
CONTACT! .
. Noyember .. 26, 1990
Cynthia Peurifoy, community Relations, [phone] ··
Charlie .Thompson, Press Office,. [phone]
.. , SOUTHolM Inc.
2000 East Pettigrew Street
Post Office Box 1491
Durham, North Carolina 27702
[phone]-FAX No. [919) 596-6438
Certified Kail
Return Receipt Requested
Mr. Reuben Bussey
Assistant Regional Counsel
January 21, 1991
U. s. Environmental Protection Agency
345 Courtland StreetL,---=N~·=E~------Atlanta-;-GA-30365 ---< Re: Jad~~Hughes-Superfund Site
----=NOYth73elmont-;-Nort:ncarol1na
Dear Mr. Bussey:
I received today a letter from Don Guinyard enclosing the PRP lists.
Please be advised that we have absolutely no records or knowledge of
any dealings with the above firm, firms·, or people indicated. in this
correspondence. Southchem is a chemical distribution firm, and
therefore not a consumer or a generator of toxic or hazardous
substances.
We are enclosing copies of our 1985 correspondence concerning this
matter from our President, J. H. Collie, our Accounting Manager, and
also our letter of December 31, 1990.
Please accept this as our good faith answer to your agency. You can be
assured of our help in any way. At this time we cannot find any
information linking us with any firm or anyone involved with the
referenced site.
HJC:lk
cc: J. H. Collie
Very stn.cerely yours, ----/. C2/!,· -~ /7 <~---
/ ~-,2..--,---.., ':-, l ~ Harriet S. Cates
Vice President -Administration
William L. Meyer, NC DEHNR
Enclosures:·
Durham-Raleigh, NC New Bern, NC Greensboro, NC Lynchburg, VA Chesapeake, VA Florence, SC Spartanburg, SC
·(Ill SOUTHc.., Inc.
2C00 Ecs: Pert1grew Sireei
Pcsr Ctfice Box 1491
Durr.cr:1. 1'Jo11h Ccroiinc 27702
[phone]-F,,:.;< tio [9'9) .5c;,::-,:.:'.?.S
Mr. Reuben Bussey
Assistant Regional Counsel
December 31, 1990
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Jadco-Hughes Superfund Site
North Belmont, North Carolina
Dear Mr. Bussey:.
Our records show no dealings involving Jadco-Hughes. Please see copies
of 1985 correspondence to your office concerning this matter.
You can be assured of our help in anyway, in the event that you find
information linking Southchem with the referenced firm.
HSC:lk
cc: J. H. Collie
Enclosures: 2
Very sincerely yours,
,,----.. (. ----~ (__~; -;,--~ -'< .:-::<~.,,.i.,c:_~· ... _/· \ a_..L-<~
Harriet S. Cates
Vice President -Administration
F!orence. SC Soartcnburq, SC
.~1,u,rtR
"'t"'ll~ . .:i
•
SOUTHCHEM Inc.
Ou.-no:-r,. t-.Jonh Ccrclina 27702
(919) 596-C<'.>81
CERTIFIED M!\IL -RETlffi RECEIPT REQJESIB)
t-t. Paulire F. ~rscn
U. S. Envircmart:al Protection t,grr.y
\e.ste M3nag:mm Divisiai/ERRB
Investi gatirn ard UlrlJ I ian:e S:!ctirn
345 Crurtlard Street, N.E.
Atlanta, Go\ 30365
RE : Jadco-f-Lg"es Site, ~Im:rrt, N. C.
D:ar Ms. ~rscn:
•
Pug.Jst 5, 1~
\.e are pleased to respa-d to yrur letter of J.Jly ll arcemirg the possible irMJ!vererrt by S::l.rt:hdm
in the transµJrt, treatrrent, or disJX)sal of hazarocus std:Jstan:es at the referen::e site.
Altl'aJJl rur rer..ords initially irdicate no irMJ!verertt with the finns or l):'C'Ple irdicated in )Wr
letter, -.e are investigatirg as far back as possible so that -.e can give yru the rerefit of all the
irifonratia, that -.e flilY have. This 10J!d in::!LKE any correspnEnee or even teleptrre rreros. For
yrur irifonratia,, ::cuth::hem is a chemical distriMia, firm, ard therefore mt a ca,surer or a 9=1Erator
of toxic or hazan:bls std:Jstan:es. ve have aided rur OJStarers in firdirg locatims for the treatrrart:
or disp'.lsal of sore of their hazaro:us llil.terials. At this JX)int, -.e oo rot recall any 9.x:11 transactims
. with or for any OJStaTErs at the site irdicate::L ,t,gain, investigatioo cr::ntirues.
Please accept this as OJr gx:d faith answer to yrur a!J=ll:y, ard that -.e will advise yru of any
irifonratioo cootrary to vilat is preserrted here at the earliest rrrnent. Yw can re assured that -.e
will help in any way, in the event that yru fird any irifonratioo lirkirg us with any firm or anycre
in"1Jlved with activity at the referen:ed site.
Very sin::erely yrurs.
J. H. Col lie
J-C :b..l
~-. SOUTHcHEtf Inc.
2000 ,osl Pettigrew Street
Pas: Ottice Box 886
·oumom. No~r. Corol,no 27702
[phone]
Mr. Charles H. Tisdale, Jr.
King & Spalding
2500 Trust Company Tower
Atlanta, GA 30303
Dera Mr. Tisdale: .
August 22, 1985
In response to your memorandum dated August 19, 1985, please find enclosed
a copy of the letter from Mr. J. H. Collie, President of Southchem, Inc.,
to Ms. Anderson of the U. S. Environmental Protection Agency, Waste
Management Division/ERRS. Our records indicate we had no involvement with
the Jadco-Hughes site.
We will continue to research our records and will be glad to furnish you
with any information we may find.
Sincerely yours,
0 /.°l/L... _,,/..:-;,____ -{j>1;,(__ v::-F .:..(_
Garey R. Cooke
Accounting Manager
GRC:bw
cc: /4 H. Collie
Gil Steadman
•. • E..-;StAT[~
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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
William L. Meyer
Director
Mr. Robert Jourdan
North Superfund Remedial Branch
EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
November 9, 1990
RE: Jadco-Hughes Superfund Site
North Belmont, North Carolina
Dear Mr. Jourdan:
I am v.Titing in response tC>_ your letter dated October 23, 1990 regarding ,potential damages to natural resources resulting from a release of hazardous substances at the Jadco-Hughes Superfund site. The Division of Solid Waste Management wishes to exercise its right to participate in the investigations at the above referenced site as well as the negotiations with potentially responsible parties.
Please contact Lee Crosby (919 /733-2801) or Jill Hickey, Assistant Attorney General with the NC Department of Justice (919/733-8352), so that we may discuss how our activities might best be coordinated.
We look forward to working with you and your staff.
cc: Barbara Benoy
Reuben Bussey, ORC
Curt Fehn
Sincerely,
-a)~ 'd-ffiA1.k(___/
William L. Meyer
• UNITED STATES ENVIRONMENTAL PROTECTION AGENC'f
4WD-NSRB
Lee Crosby
Superfund Branch
North Carolina
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365
Department of Environment, Health and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
Re: Jadco-Hughes Superfund Site
Record Of Decision
Dear Ms. Crosby:
Please find enclosed a copy of the Jadco-Hughes([~cord of Decision.
This Decision Document completes the requirements of the Remedial
Investigation and Feasibility Study for the site.
Please contact me if you have any questions concerning this letter.
I can be reached at 404/347-7791.
Sincerely,
/)
I ' /,,-,,
/ \ ! ',., ,'
/ . !J ,, ',, : ( :>: !
Barbara H. Benoy
Remedial Project Manger /
Waste Management Divisiori
Enclosure
cc: Bill Meyer, w/o enclosure/
Jack Butler, w/o enclosure
Bruce Nicholson, w/o enclosure
I.
!"
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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
Mr. Greer C. Tidwell
Regional Administrator
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
24 September 1990
RE: Conditional Concurrence with the Record of Decision
Jadco-Hughes NPL Site
Belmont, Gaston County, NC
Dear Mr. Tidwell:
William L. Meyer
Dircclor
North Carolina appreciates the opportunity to comment on the Record of Decision
(ROD) for the subject site and looks forward to working with EPA on the final resolution
of the problems at this site. The State concurs with the attached draft ROD and Remedial
Alternative Selection for the Jadco-Hughes Site, Gaston County, Belmont, North Carolina,
subject to the following comments, conditions, or exceptions:
1. Because off-site private wells have been found. to contain site contaminants
below the MCL, it is imperative that off-site private wells be included in the
groundwater monitoring requirements, regardless of whether these wells are
currently being used for drinking water or not ·
2. Because soil flushing is proposed as a soil treatment, the remedial design
should also include provisions for initiating in-situ bioremediation in
conjunction with soil flushing. This approach may produce additional benefits
for little additional cost
3. The draft ROD states that the UV-ozone treatment is the selected
contingency alternative to be used if the Belmont POTW will not accept the
pretreated groundwater. We are concerned that this technology is not proven
to be reliable. If the Belmont POTW does not accept the groundwater, we
• •
Mr. Greer C. Tidwell
24 September 1990
Page 2
advise that a thorough review of treatment technologies be conducted to
establish whether UV-Ozone treatment is the best suited for the task (as
opposed to steam stripping or air stripping, for example). If UV-Ozone
treatment is ultimately selected, we request that there be no less frequent
than weekly monitoring of the effluent discharge in the first 3 months of
operation to establish the technology's reliability and ensure compliance with
the NPDES permit.
4. State concurrence in the Record of Decision and Remedial Alternative
Selection is based solely upon the information contained in the attached
Record of Decision and Remedial Alternative Selection. Should the. State
receive new or additional information which significantly affects the
conclusions or remedy selection contained in-the Record of Decision and
Remedial Alternative Selec.tion, it may modify or withdraw this concurrence,
effective immediately, upon written notice to EPA Region IV. Such notice
shall contain a statement of the reason or reasons for the modification or
withdrawal of State concurrence.
5. State concurrence in. this Record of Decision and Remedial 'Action
Alternative Selection in no way binds the State to concur in future decisions
or commits the State to participate in future activities regarding this site
including but not limited, to remedial design selection or State participation,
financial or otherwise, in the clean up of the site. The State reserves the right
to review, comment and make independent assessments of all future work
relating to this site.
Again, the State appreciates the opportunity to comment on the ROD, and we look
forward to working with you on the remedial design.
Respectfully yours,
-1{)~ ;;l-170;.vu
William L. Meyer
WLM/acr
cc: George Everett
Enclosures
Fax Record
North Carolina Department of Environment, Health, and Natural Resources
Solid Waste Management Division
From: ____________ , Solid Waste Management Division
_________________ , Solid Waste Section
---=-,-----..,.------------' Hazardous Waste Section
_1,.u..:ce.::.:u'-'c..."-'£~_.N...:...:.:IC.."'-'-'H:QLS.>£>==-=o:J.N..,,,_ _______ , Superfund Section
Date:
Re: -=~f-A•)Co-=+fv (:rltt:S-::-_,,. l(o .D L-ON C, u {Q..t,N CJC. it-
No. of Pages (Including Cover) 3
Division of Solid Waste Management
Hazardous Waste Section
Superfund Section
Solid Waste Section
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FAX NUi,!8£R, FTS 257-2684
COM.V.ERGIA (, 404/ 34 7-2684
PLE~5~ CONTACT 404/347~7791 if any proble~s occu~ with thls
tran;;mlttal.
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F?~{ NUM3ER, I 91 <} 7;) 3 -· 1/? I I
FROM: _.lli! r.b.:i r.a H. Bt=:t-9Y I. J{~:r,ed ta, Project H.c.r.aqe.r
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A aecurity fance i~ei.ng inst1lled under the Intel l'\ction Soil
Removal Program and ia being pla•oP.d along the perimeter or th"'
property boundary. This will reitrLct unauthorized accasa to the
oita as well ao to the treatment •area ultimately minimizing the
potential for direct human canta:t with any residual contaminated
media at the aite.
The goal of this remedial action is to restore groundwater to it•
beneficial use, which ie, at this •ite, a potential drinking water
source. Based on information obtained during the RI and on~ care!ul
analysis of all remedial alternatives, EPA and the state of North
Carolina believe that the eelected remedy or the contingency remedy
will achieve this goal. It may become apparent, during
implementation or oper,.tion of the groundwater .a,ctractl.on ayetem and
ita modifications, that contaminant levela have ceased to decline and
are remaining conatant at levels higher than tho remediation goal
over some portion of the contaminated plume. In such a c"se, tha
ayatem performanca standards and/or the remedy may be reevaluated.
The eelected or contingency remedy will l.nclude groundwater
extraction !or an .astimated period of JO year•, during which the
system's performance will be carefully monitored on a regular basis
and adjusted as warranted by the per!ormance data collected during
operation, l!odif ications may include:
a) alternating pumping at wells to eliminate stagnation pcl.nte;
b) pulae pumping to.allow aquifer .aquilibration and to allow
adsorbed contaminants· to partition into gtoundwater;
c) installation of additional extraction well• to facilitate or
accelerate cleanup of the contaminant plume; and
d) at individual welle where cleanup goals hav.a been attained,
and after analytical confl.rmatl.on, pumpin9 may be
discontinued.
To ensure that cleanui;i goalo continue to be· maintained, the aquifer
will be monitored at those wells where pumi;iing has ceased on an
occurrence of every year following discontinuation of groundwater
extraction.
It, in EPA'a judgment, implementation of the selected r.,medy clea.rly
demonstrates, in corroboration with etrong hydrogeological and
chemical avidence, that it will be technically impracticable to
achieve and maintain i:emediation goals throughout the area of
attainment, a groundwater remedy contingency will b.a de•,eloped and
implemented. For exam~le, a contingency may be invoked when it has
been demonstrated that cont~ninant levels have ceased to decline over
time, and are remaining constant at some etatiatically eignifl.cant
level above remediation goals, in a discrete i;iortion of the area of
attainment, aY verified by multiple monitorl.ng wells.
. . ' • •
Community Relations Activities
The majority of public interest and partlcipatio~ occurred during the
years of e.ct.iv9 operation and oubsequent cleanup. Citizeng were the
source of pres~ure that resulted in the State ordered cleanup
completed in 1978. once the main p,;oblems associate,d wi.th the
operations on tha site, such a.s the termination of incineration
operations, removal of thousanGs of drums as well as numerous large
otoraga tanka, and the elimination of spill• and fish kill• that were
,_;:,~,.r1.•ed by the resideots, public involvement decreased.
Essentially, their pri.mary objectives had been met.
During the inve9tigationa of 1983 and 1985, selected r~aidenta were
informally int~rviewed when field personnel were sampling i.n the
area. Some of the citizens allowed their well• to be teated to
determine whether groundwater contamination had migrated from the
Bite.
Formal community relations were initiated by EPA after the RI/FS
proces5 began with the development of a Commun!.ty Relations Plan.
Several Qite specific fact eheets were distributed to the area in an
effort to keep citizens informed.
Two public meetings have been held near the gite; the Hrat meeting
was he"d to present the results of·the RI in November of 1989. The
second public meeting was held in July of 1990 to present the
Propoeed Plan and to initiate the formal comment period. The
Administrative Record was made available at the Information
Repository. This Information Repository has been maintained for over
a year at the Belmont Branch of the Gaston County Library System.
Public Notice was published prior to the meeting and also announced
the apecific time frame of the Public Comment P<,riod, which was July
26, 1990 to August 24, 1990.
The Reaponsivenesa Sununary, which compiles all comments received
during this period, in included as Appet1dix A. During the course o!
investigative and remedial activities at the aite, federal respons~
to community need$ and concerns hae been pe1:cei•1ed as sufficient.
Criticism has predominantly pe~tained to the ler.gth of tl1e Superfund
process.
scope and Role of Resoonse Action
This ROD addrcasseg the final response act.ion for the Jadco-Hughee
Site, which consists of extraction and treatment of contaminated
groundwater, treatment of contamLnated aoile onsLte, elimination of
eurface water contamination by aurface watel:' diversion and culvert
replacement. Additional institutional controls and access
restriction will be taken to complete the remediation at the eita.
Period\'C monitoring will be conducted until all requirements as
·'
U~i• ST."-TES E,,:v:RONMENTAL PRO-Tl/Ji': ,0,GENCY
R::'.GION IV
34~ COUP rLAN:) STREET. N.S:.
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FAX COV~R S!lEE'i'
PLEASE DEL!VSB IMMEDIATELY
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FAX NTJM$ER.: FTS
COHMERCIAL
PLEASE CONTACT 404/347-7791
TO: C)ac/(
LOCI\TIOi?:
if a.ny problems occur with this
transm!._ttal.
FAX NUMBER, _____ _
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FROM; J?-~!J~,r•~-~er~oy 1 __ Reme~ial ?ro~ ec~ _M_a;i~qe~
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Gro.dwater Remediation Goals
Jadco-Hughes Site
Chemical Clean,iJ2 Goal
Organics (ug/1)
Acetone 700
Benzene 1
2-Butanone 170
Carbon Tetrachloride 0.3
Chlorobenzene 300
Chlo re thane 10
Chloroform 0,19
1,1-Dichloroethane 0.3
1,2-Dichloroethane 0,3
1,1-Dichloroet.hylene 7
1,2-Dichloroethylene (Total) 70
1,2-Dichloropropane 0,56
Ethylbenzene 29
2-Hexanone 10
Methylene Chloride 5
4-Methy-2-Pentanone 350
Tetrachloroethylene 0.7
Toluene 1000
1,1,1-Trichloroethane '200
1,1,2-Trichloroethane 5
Trichlorethylene 2.8
Vinyl Chloride 0,15
Xylene 400
Benzoic Acid 28,000
Bis(2-chloroethyl)Ether 0.03
Bis(2-ethylhexyl)Phthalate 4
1,2-Dichlorobenzene 620
1,3-Dichlorobenzene 620
11 4-Dichlorobenzene 1.8
Di-n-Butyl Phthalate 0.4
Phenol 4.2
1,2,4-Trichlorobenzene 9
! the
Basis8
RfD
NC
NC
NC
-Neb
CRQL
NC
NCC
NC
NC
PMCLd
NC
NC
CRQL
NC
RfD
NC
NC
NC
PMCL
NC
NC
NC
RfD
CSF
PMCL
NC
NC
NC
PF
RfD
PMCL
'DRAf1_,
~
. ~ • Chemical
(ug/1) I) Cleanup Goal !;l_asisa
Inorganics
Aluminum 50 PSMCL
Antimony 3 PMCLG
Arsenic 50 NC
BariUlll 1000 NC
Beryllium 1 PMCL
Cadmium 5 NC
Chromium 50 NC
Iron 300 NC
Lead 15 RCG
Manganese 50 NC
Nickel 150 NC
Vanadium 20 RfD
Zinc 5000 NC
RfD ~ Reference Dose. This is the systemic threshold concentration
calculated as Reference Dose (mg/kg-day)* Body Weight (70kg)*
Relative Source Contribution (, 10 for inorg0, nics; . 20 for
organics) /Daily Water Consumption ( 2 liters· .
NC e North Carolina Water Quality Standard Au;ust 4, 1989
CRQL = Contract Required Quantlfication Limit. •.rhis is the
quantification limit specified by the Contract Laboratory
Program.
PMCL"' Proposed Maximum Contaminat Level
CSF Carcinogenic Slope'Factor. This is the concentration which
corresp~nds to an incremental lifetime cancer risk of
1 X 10-•
PSMCL Proposed Secondary Maximum Contaminant Level
PMCLG • Proposed Maximum ContamJ.nant Level Goal
RCG • Recommended Cleanup Goal for lead at Superfund sites
(correspondence from the Directors of the Office of Emergency
and Remedial Response and Office of waste Programs
Enforcement, June 21, 1990)
a
b a
C =
d =
The North 8olina Water Quality Stand-ct was us.sect as the
remediation goal for all chemicals which have a promulgated
standard. If ,.a North Carolina Standard was not available,
the following hierarchy was used to establish cleanup goals.
(l) PMCL or PMCLG (for nonzero PMCLGs)
(2) PSMCL
(3) Health based values using RfD for noncarcinogens and CSF
for carcinogens
(4) Contract required quantitation liJnit
The proposed MCL for chlorobenzene is 100 ug/1,
Due to structural similarities, the North Carolina Standard
for 1,2-dichloroethane was used for 1,1-dichloroethane
The goal represents the PHCL for· cis-1,2-dichloroethene
DRAtU
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•
DECLARATION l'OR T.HEJ RECO!U) O!' DllCISIC•N
Site Name and Location
Jadco-Hughea Site
North Belmont, Gaston County, NO)'.:l:.h Carolin-a
statement of BasiB and Pu,;:poaa
Thie decision document repreeenta tha selectect i:-ernedial ax:tion for
tha Jadco-Hughas Sits, located in North Belmont, NOL'th Carolina,
doveloped in accordar.ce 'fith the Compr~henaiva Environmental
Response, compensation, and Liability Act of 1980 (CERCLA), as,
amended by the Super!'und Amendmenta and Reauthorization Act of 1986
(SAP.A) 42 u.s.c. SactiOr'l 9601 et. eeg,, and t.o the extent
practicable, the National Oil and H~zardoua Subatances Pollution
contingency Plan (NCP), 40 Cl'R Part 300.
Thia decision is baaed upon the contents of the Adrniniatz:ative Re=cvi:-d
tor the Jadco-Hughes site.
Tho State o'! of North Carolina concurs on the salected 1.·emGidy.
ABeessmsnt of tha Site
Actual or threatened. releases or ha:iurdoua substances t'rom th.la site,
if not addreea_ed by implementing the reeponse action selected 1n t,hia
Record Of D_acision (ROD), may present an imrninant and substantial.
endan9e.z:rnent to public health, welfa.ra, oi: the environment,
Description of the seleoted Remedy
This remedy ia the tinal action tor the aita. It addresses the
groundwate!:'" contamination, which conet:it.utes the pL·incip~l health
thrnat remaining at the Rit~, o.e well ae: the remo.ining soil
contamination, which continues to be a aource tor groundwater
contamination. Gi.·oundWater remediation will be accomplished by
pumping and treating c;ontami~ated groundwa.tt\-r, Trea.te9d groundwotor
wil.1. bs dlschargad to a publicly-owned treatment war.ks (E"OTW). '!'hs
discharge ot cont=inatio_n · into surface water will be addressed by
the diveroion of the flow of eurface water a.nd L·epla.c:ement of an
on site culvert. Soil treatment will be conducted in aitu with a Boll
Vacuum extraction sy"ate:n followed by aoil flushing.
The majo,: componente of the selected c·emedy inc ludo:
o Institutional Coil.trola a.nct/or Othor Land. UEia RastrictionBJ
o Groundwater Monitoring
o Groundwater-Recovery ·via Extraction Walle and tile ctrai.n (a};
o Groundwater 't'i:eettment vio. Aeration and carbon Filtration to
~r8-Trea~ment standard~;
o Discharge of Treated Effluent to the Belmont POTW-,
o Treatability Studies to Ensure compliance with POTW
Pre-treatment Standar<ls1
• •
o BaCkup Diecharge ?lan,
o Soil Va.par Extraction fol.lowed by ca:r.~bon ~dAorption of
removed vapor;
o Soil Fluehing by inti;oduct.ion uncontaminated \~•a tar 1
o Replaciament of Oneite culvert;
o Redi:r.~ection of spring ws.ter flow;
o Qurterly monitoring of the site, to inolud~ groundwatel..',
su1.·face wfl.ter, aediments, and eoil~; and
o Review of Groundwa~ec Uea Every ~ivA Yeare.
El?A. has also selected a C?ntingency altarnative, in the ~vent that
the POTW does not agree to accept t.he disc1·1a1:ge.
'!'ha major: components of t.he contingency rsrnedy in.cli.1de:
0
0
rns1:.ituti.onal Controls and/or Ot:.hsr· Land Uee Restrictiona;
Groundwater Monitoring
o Groundwater Recovery via Ext:.l:."fiCtion Wells ,5.nd til.~ drain(!!:) I
o Gt·oundwater Treutmen-c involving Prl!'l-troat:.ment for met.al.s
followed lJy Ultraviolet Ox:ictization to Prtt-Treatment
Standarde,
o Surface water Oiscl1arga of Treated Effluent;
o Treatability Studies to Eneu>'e compliance witt1 Surface Water
Di~ohar9~ Criteria;
o soil vapor l!xtraction followed by carbon adsorption of
removed vapor,
o Soil .Flushin9 by int1.-oduct:..:!.on uncontaminated wc-.te-r; o.nd
o Replacement of oneite culvert/
o Redi~ect£on of nprin9 water flow;
o Qurtetrly rnoriito.t:ing c,£ tha a.1.te, to include g1:cundwateii:,
au~f~ce water, eedimente, and soilst and
o Review of Groundwater·uae Evei:y Fiva Yea~a.
Statutory D8term.ination~
The setlected and contingency remediee: are p;::otact:ivtt of human health
and the environment, comply with Federal and state requirementa that
e1.1.-e legally applioab.ls or relevant and app:t·op.t.·iate to the remadi,!1.l
action, and arl!l coat-effective. These remediea utilize pei:-ma.nent
solution~ and altsrnatlva treatment (i:..1.r r.esource tecove.cy)
technologies to the maximum extant Practlca.ble and Batiefy thl;..!
atatutory pre!e::encs for remedies that employ t1·eatment that reductH1
toxicity, mobility, or volume ae a princip~l element. OecaufH, these
remedies will not result. in hazardous oubetancee remaining Oli th"
eite above health-baeed levele, th~ tive-year review will not apply
to this action.
GreeL· c, Tidwell, Resional lldminiot,:ator Date
•
DECISION SIJHHARY
Site Location and Description
The Jad.co-Hughaa Sit.a ir.i looated r)n Caaon St. in an unincorpoi:a.tad
area of North Belmont, :Gaston County, North Carolina (figure l).
Belmont ia located about 15 miloEJ west of Cha"Clot.te, Noi;th Carolina.
:rhe Jadco-Hughea site .la approximately Bix a.ores in ~iz.e. D!.aposal.
and storage practices _Wt,re conducted throu9hout the six ac,:;;1a,
Figure 2 shows hiatorioac featurea of the aite. ReeLdential houaing
ia located immediately noc·th of the aite,
Land. uee ot the immediately sur1:oundlng area!! i.o a mix~\.11:e of
residential and industrial developments. Huch of the area
surrounding the site remains forested, tl\ough the area is
experiencing growth and davelopment alor)g wit.h l:lHit entii:.e "Meti:olino.
Altea.". AccO~ding to the 1980 censuu, Go.1;JtOn count.y had a populatlotl
of 162, ~68 which represented a growth =ate of 9. 5% elnca 1970. The
numbor of houa:ing units 1ncreaaecl by 28.2% ovei: thCJ ea.me p~riod. The
1980 J?OJ?Ulation for Belmont wae 4,607; neil.:.he1.· Catawba Heighte nor
North Belmont ware liated 0epa.rataly. Approximat.ely 30 f.a.milies livt!'!I
within the immediate vicinity north of the eite.
Groundwater and surface v,a.ter are both used for potable water.
Publ!.c drinking water ouppliee a;i;·e drawn predominantly from the
Catawba. River. GroundwateL~ ie not used aa a drinking water aupply
onsite but is a water 8Upply raROu~ce offaite for rsaidente having
operational wells installed pz.•ior to the provision of municipal water
oonnectione:.
Two unnamed tributarioa flow through and/or adjacent to tho i,ite,
Tributary A !lows in an eaete:t:"ly direction along the no~th 15ito
boundary. Tributary B !lows through a buried culv&rt in a northward
direction. '.rhe confluence o! the two ti:ibutariee cont.inue flowing lt1.
" northerly direction merging with l"ites CL·eek and ultima,:aly flow.ing
into the Catawba River. Figura 3 ahowa the surface tributaL~iee tu,
well ao cu~rent eit~ condiCticno.
A flowing spring ie located juet eaat of the 9ite proper. Thie:
spring hiatorici,lly flowed riorth and wast and merged into tL·ibutary 13
downstream ot the mouth of the buried culvert. D~ainage from thi~
spring currently flowi, acrose the fo1.~mer ope.i:ationl! area, and
discharges into Tributary B,
'l'here are no designated North Cai.-olina st.att!I si911iftcant Ht1.bitate,
nor historic landmark eites directly or potentially affected by the
site. ~here are no endangered specie~ or critical habitats within
close proximity Of th& ed:ta. There ai:a no identified coa~tal or
fr:eah-water wetlands within an area of influence of tht!I aite.
The 9solo9ic setting of the portion of Gaaton County near the site i3
dominated at shallow depths by the crystalline Rock Aquifer which is
the principle aquifer in the Piedmont phyaiographic pr:ovim,e. Two
• •
distinct water-b~aring zonee exiat beneath tl1a eica, the b0drock
aquifer .e.n6 the, uppar uaprolite aqulfe1.·. Data generated du1:ir'l.9 thtt
rtamsdial Investigation (R!) confirmed that thara is no con~ininQ zcno
bet·.4een the two aquifers and therefo1.,e, thae0 two zoneo A1:e
considerGd hydraulically ·connected. Resulte of the RI aleo indicatod
that the predominant direction of gr.,;:,undwatel;' !l~w ia to the north.
Sita Hietocy and Eoforciement Analyeio
'l'he Jadco-Hughes e.1.t:.9 is. located in North Del1(lOnt, Hor.:th Carolina.
The six .... ~cre site is a' former eolvent reclamation and waste storage
facility operated by C.R. Hughes, Inc. from 1971 €0 1975 and later
leased to J'adco, Inc. ~ntll opei.-atione: wei:e eutspen.dsd and
coneaquently terminated in 1975. .Aerial. photog.ca.ph~ in.dica.taa that
the facility was active aa early a~ 1969, During ite oper~tion, the
eiti_, recltd.!lled uesd waste paint Clnd. ink-typ~ solventB. It alao
stored drummed n,a.l:.e:L·ial consisting of "\any wo.et~ ~ubstanco.a including
waste chemicals and chemical waat& eludges f!.·om !lrea. induetriee.
The Stata of No-!='th Carolina ordered th-a f'iite t.o be closed in 1975
aftar numerous complairits by neighboring residen-ta and the
docum~ntation of fraqu~nt apille. during ti'.e years o!: operation. !n
addition, the State oi:darad tha facility to be cleaned up and pursued
proper mana9ament of the cleanup under existing State and Fec!ftral
lawo, Reiportedly, the cleanup included the excavati.on cf two
in-ground pits into which solv{:,tn.ta· we;;e plo.ce.d. Aleo, oneite
contaminat.:eid surface soil waa coneolida.ted ~nd covered in an onaite
landfill located in the aouthweBt gu11drant of tba ~ite, AU
remaining large etorage tank a, a mobil& t.&nker, and numerous l.·eaidual
drumi, Were removsd in 1903.
In 198.3, the EPA initiated a suparfund alts investigation, Thia
investigation analyzed Surface water, eedlmant, soil, and groundwater
eamples, 'rlla data collected wu:ca t!valua.ted using t.:he Hazard Ranking
syetem (HRS). '!'ha resulting HRS a:::ore wae 42 .00 and renect .. d tha
potential for groundv,a.ter and sur!ace water contamination. he a
reault, the EPA finalized the eite'a placement on th8 National
Priocities List (NPL) in 1986.
Subeequently, EPA nagotiatad with a numbe~ of the compani~s, or
potentially rasponoibla paz:t.tes (PRP-s) that had conducted l)u~inese
with Jo.dee, Inc. and C,A, HUIJhea, !nc, to psrfm:m the Remedial
Inveatigation and Feasibility Study (FS), or RI/FS. ln Septamber
1986, an Adminiatrat~ve Order on Consent was agreed upon by' EPA and
the PRP Steering committee. The Rdmlniotrativa Ordar outlined the
terms under which EPA would al low the PRP steering C01l'uni t tee t.o
conduct the RI/FS,
The first draft RI Report was submitted to the l\gsncy in o .. carnbar of
1989. A final RI Report wo.e approved by EPA in August or 1990.
Community Relations Activities
The ma;ority ot public interest and partioipation occurred during the
yerare of: active opa:..·ation and eubeequent-cleanup. Citizens were the
source of pressure that rsault8d i:1 tha Sta.ta ordered cleanup
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complatsd in 1978, once tha main p£oblema asaociatod with tl1e
operations on 'th~ sita, auct1 as tha t&rminatio11 of incineration
operati~ne, removal of thouBande of drume as well aa numeroua large
storage tanks, and the elimination of Hpills and fieh killa that were
observed b:t the ·ra8idents, public involvement dect·aaaed.
Ee:aent.ially, thei.:: prJ..mtu:y objec~iveo had beien met,.
During the investigations of 1983 and 1985, ae)..ect.ad rss!.dente we.t.-e
informally intarviewe:d wl1sn field pernonne.!. w~z.-e sa.n,pliny in the
araa. some of the citizens allow·ect their wells to bie teetad tc:.,
deter1nins •,vb.ether ~roundwatei: contamino.tion hod' migratod from the
Bite.
Formal community relations were initiated by EPA. after the R!/FS
proceue began with ths davalopment of a,Comrnunity Rl!illl.tion:!I Plan.
sevoral eite apecific tact sheets ware diatributed to tl1& ar~a in a11
effort to ktiH:tp citizens i1tformed,
Two public meetings hayR been held ne~L-the Bitei t.her fi.ret meeting
waa held to present the reaulta of the RI in Nove11'.ber of 1989. Tbe
second public meeting waa held in July of 1990 to present the
PropoSed Plan and to initiate the forniiJ.l com.ment pe1:iod, The
Adrnini~trative :Rec:or,\ wae mat:lei availa.bl0 at. the :r.nfo1.~ma.tion
Repository. This Information Repository has bean maintainad for ovec·
a year at the Belmont Branch of the oaaton-county Library Syatem.
Public Notice waa publiehed prior to the meeting and also announced
the_ BJ?eCific time frame of the Public comment Per J.od, which was July
26, 1990 to Auguet 24, 1990,
'l'he R00ponaiven,e,as ·sw1u\,a.ry, which compilee oll comments 1:eceived
during thiB period, in included as Appendix A. During the cour~e of
investigative and remedial activitiee at the site, federal response
to community needs and concerns has been perceived as autticient.
crJ.ticiem has predominantly pertained to ths lsngth of the Superfund
proceaa.
Scope and Role of ReeP9nse Action
Thia ROD addree_aew thw final. r~iiiiiponliO action for the Jadco-Hughes
Site, which consists ot extraction and traatmant of ooni::aminated
groundwater, treatment of contillf\inated soile oneite, eliminatiOn of
eurface water contamination by eurface w~ter dlvereion and culvert
replacernemt. Additional J..netitutiono.l cont robs and ·a.cce9e
restriction will be taken to complete the remediation at cha site.
Periodic monito1:in9 will be conducted unt.il all L·eq1.d1:ements as
preeented by thie ROD ar~ met. The reepon~e actione are consiHtont
with the National Conting0ncy Plan (40 Cl!'R 300, 68).
Sita Chara9tftrietic9
Information available rrom state and Gaston county filea as well aa
aerial photography were used to hel.p characterize ths site. Surface
·drainage in the area of the site flows to the north. Tributary B
transects the site and intersects tributary A at the north end of the
site. Figure 3 shows current site featureo. The stream continues
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north to Fites cr_eeJt 1 approximately O.8 milea (1.3 km) away. Fiteu
c,·eek joins the Catawba River appro><imately 1.5 milee (2.5 km) awai•,
Tha 0ite is underlain by approximately 100 feet of eilt.y sands, aandy
ailta, clays and si.lts contain~ng variable amoun1.:a of unconaolidAted
granite, diorite achiet and gniess. The main gaologic unit. t1t the
site ia the Residuum/saprolite unit. 'J'hesB units were formed by t;he
in situ chemical weathering of the granit0/diorite bedrock. The
overlying Residuum ctisplay"d a higher degrea of weathering "nd· tot.al
lack of any vestiqal bedrock structure. Tha Saprolite eontaine
remnant granific/dior.itic structure auc:h as reHc quartz 1tnd feldspar
veins. Tha Rasi.duum/Saprolite unit waei described a.s red ... bi.·own to
white-black unconaolidatad fine to medium gr~J.ned sand and silt ~iztl!IJ
particles. Fluvial d.eposite: wel:;e encounte:..·ed pJ:edcmina.ntly at the
northern end of the site and coneieted of claye and silts, with
lsseeL· amoun~a of fins to medium grain aand.
The regional hydrogeoltjQy ie characte1:iz.ed ae the PiflsdmC"Jnt
phyaiographic province,_. The cryat.allina Rock .Aquifer ·1a the
princi'pal aquifer in tl1s Piedmont phyeiog.ra.phic p.t·o\•ince. Tho
eurficial aquifer ia characterized as tl1e saproli~& U11it and iB known
to be hyclt:aulically connected with the bedrock 1.<nit,
The types •Of contaminants which remain at the Jadco-Hu9has site
include volatile and axtractabla organic compounds, PCBe:, and
metale, The majority or -the vola~ile organic contamination at.: the
Jadco-Hughes site exhibits the RCRA characteristic of ignitability
and therefore may be coneide,:-ed a hazai=doua waa-t;e eiuhject t(") RCRA.
The l"CB waste ia a liated RCRI\ waote.
The RI focuaed. on the identified eite featureo, e:uch as the landfill,
overationa·area and numecoua storaga a~eaB, ae well aB d&terMining
the site impact on groundwater as well ae sui:facu water. The eit.e
characteristics have bean organized by media within this dscifd.on
document.
Soila
'l'ha soils at the Jadco-Hughes s1te ware charactarizlild by the
collection of samples from boreholes, test pits and ga::n.b samples, a.a
well ae additional screening ot sol.le with an r!Nu, which le ueed to
detect the presence of .organic va.pore in ail: by photoio1tiz.ation.
Four areas of concern to the Agancy were identified foi: invee.tigation
of sOile. Theee,ar0ae were;
o the lan<ltill ai:"a located in the aouthweatern quadrant of
the aite1
o t.he former op6rrationfJ area located in the eoutheo.ete2.~n
q\ladrnnt cf th,. Ml.t,.1
o the former decant pite:, designated the north and south pits;
o the southeastern "awale" area.7
Figura 4 ee~imatea the locati6ne of thaae area~-
co·2.1eoted from .o'~her areas of the eite· to enaurs
areas of 90il contamination were not preeent.
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Soil ea .. mplea were
that additional
Soil charactetizatl.on will be pree.,nted by focueing on each "rea of
concern, Due to th~ number of individual conte..minant~ found at the
aite, the RI focused on all con6titus11ta deLected at or g~oater than
1 mg/kg, ( or 1 pai:-t p,n: million, ppm). Thi• fortr,o.t will be
incorporated i?1to the !{co. to help delineate the e,ite cont.a.mination.
Landf i 11 Area
Ttie landfill area originated cturing the l.978 cleanup and reportedly
contains the coneol.idstion of contaminated surface eoils, excavated
aoila from the decant pits, and well au other debris. Figul.""e 4 e:hown
the approxi.mats boundariee of tha landfill, The landfill wan
charac_ter!.zed by the collection of samples from nine loc.atione. 'l'he
contamination found in the landfill e.rea wa9 prsc!om.!.na.ntly organic
compounds though aome elevated met&l concentx-a.tionfl! have been
observed. Table l preSente a aununary of the landfill ccntami.nante.
Figure 5 preoents locations of ooil sampling poi~te.
The RI datermined that phtha.la.taa, phenolic cornpo'..l.nde and
trichlorobenzana were inoet frequently detected and although a great.er
number ·of extractable organic compounds wet.·tt detected, t.he ov"l.·o.11
conceritration of volatile orga.nio oontamir,ation was greater than that
of t.he tot:al extractable organic compounds in concent1:e1.tion. !n
addition PCB 1248 w_a• detected in the la,,dfill and antimony, lead and
beryllium ware detected at co1\centca.tions above estimated backgroun~
levelB.
FOrmer Operations Area
The former operationliJ o.rea waa ue1ed for dletcillation and procei'3e:ing
of waste chemica.lB. Numerous epills v,era L'0portts1d to have occurred
in thia area and cone:equant.ly into tho ti:ibutary eyetem.
The collection of eight aoil earnplea were uaed in the forme.i.~
op{;Jra.tiona area to charactet·.i.ze t:ha aoil contamination, Se;varal main
contmninants of concer!"l were ictant lfl.ed for the fOltmer opeiration~
area. 'these include 1,2-dichloroethane, trichloroethane, acetone,
and PCB 1248. since data waa not p~eeentod fo4 all param&tero of
concern on all eight eamplef:, collected in the foi.-mer operat1.onB area,
this Record or Decision o.eeumee that the contamination in this
area may not be not limited to those fou~ constltu.enta identifieid
above. Table 2 p~qvidss the analytical data !o~ soils in the forme~
oparationa area.
P9rmer Docant Pit Areas
The decant pita ware conetructed and repoi:tedly ueetd in 1977 tu., a
place to pour contente of drums t.o allow lhe, liquids and sludgee to
eeparate, Thia allowed the liquid phaee of the wastea to be pumped
into larger capacity storage vessels and_ ultimately removed. Tho uae
of plastic ·as lining mataz:-ial waa report_e-d in. the RI, but according
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to interviewe with state officials and locai reeidenta, tl1e pita ware
aeeentially unlined. several incidents are recorded in the Stdte's
filea of thQ decant pita being leEt Eull of liquido fo~ extended
periodt, of time. seepage or contarnLnati.on most p~obably did occur,
'l'hB size of the south decanting pit was J:t:,ported to b~ appJ:ox.imately
20 faet by 8 feet w·~th an unknown depth. The size of tho no.cth
decant pit wae approximately 6 ~eat by 12 feet alBo with an unknown
depth. According to the RI, personal in~erviewa conductad with area
reeidAnte euggeated that the r1orth pit may h~ve been much larg~r and
deeper than reported; Alao, local reaidenta indicated that both the
north and south ctecant pite were at laaat 15 feet deep 8ince a
bulldozer wae observed ~o be completely hidden ,ihile inside the
pite. The Ul31:! of ths Fit a wa.e diecont.!.nued following a. l'Jtate
inspection in. 1977+ The RI aleo repo~te: th.al: t..he pits weir~ pump6d
out, lim8d and backfilled,
sample~ were collected from eeven locations in each decant pit area
to characterize the eoils. '.!'able 3 and Figure 6 provide t.ht:1
1oca.t!.one and tabulated data of the pit areas. aaeed on the findings
of the RI, the decant pite no longer constitute a source of
groundwater conta:nination, SoLla fro:n the clecont pita will not be
further remediat0d.
The results of Phase I of tha RI, indicated the eoutheastei:n area of
ths site, also known aB the "swale" a.rsa, 1:&qui1.~ed further
invoetigati.on to dBlineate the, extent of PCS cont.amination or euL·face
soils. Thia focused portion of the RI ie presented in the Surface
Sediment Aseessrnent of tha RI. Thia ROD cot1aide.rei this tu:ea of
co~ce~n ~nder tha ~oile charactori~ation of the aita.
concentrations of _PCB wera obe:erved up to 1500 mg/kg, (ol.~ ppm). As a
reault, the l?RPs auggestsd an inte1:im romov.:,.l eoil pro92:"am and
entered into an Adminietrative Order on Con~rnnt with the EPA to
conduct t.he removal. The final Interim soil Removal Progi:am la
attached ae Appen<lix 8, '!'ha Soil Removal Progro.rn eatablif1hes t.ha·
cleanup goal for PCBe o.t 10 mg/kg. 'l.'hia cl&anup goal was dei.-ived
!rom tha tJSE~A PCJ:3 Claanup Spill Policy and will be conducted in
acoordanoe to TSCA. '
Bµrf&ca Water and S&di.m&nts
As described earlier, the sita has u tributary E1yatern that !lowa
adjacent to and/or ,through the aite. Th0r0. ia also a flowing spi-ing
from the property just ea.et of the aite boundary. Thtt confluence of
theBe thres water eyetsrne flowa nor:thwanl until it mergetJ with Fitaa
creek and ultimately dischar<]BB into th .. Catwba River.
,Hietorica.l recorde provide information concerning unaut.ho.t.· ized
die.charges of waste rnate.i:io.l.e occul.~i:ing at regular inte1:vale du~in9
!acility operations, At least two fish kills ware considered to be
cauBed by Burface water violationa from the eite during active
operations.
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surfacs water and aedimant samples waea collected in un effort to
establish background. conctitiona al3 well al:J to chai:actei.-ize the n~t.ui:-~
and extant of contaminai:.ion from the site. Su,:face wate1: sampling
~eaulted in the identification of surface water contamination,
predominantly· of organic compounds. Table 4· liate th6i,e
contaminants. Figura~ showa the locat.lona of a;1 aurface watar and
aedim_ent sampling loca~ions. The ciature of t:he contamination
indicates that the impact; to surface wC1..ter may be frorn groundw8.te.r
discharge via tha damaged oulv1;n·t OX'.' from eur:fa~e water 1,.~unoff
currently flowing acroBs ths !:01:mer ope1:atione area. The
contwnination detected in tha surface wate1: ie aimi.lar to the
contamination round in the, 91:oundwAter, but at much lower
conc911trations. An additional eource could be the surface flow fJ.:om
the apring o.cc1.·oe;e: the former oporationo a~e,a.
1l'he concentrations ot. the site contcuninante that were detected in the
eadimsntation of the tributary ayetem we1:e very low. Elimination of
the potential eourcee of the oont.a.rnination entet·in9 into the eurf.aco:
water eystem ia included in the eite rernetly. 'l'.'here-foz:e., eedimen-t in
the tributary ayetems are not baing considered for further
remediation. Monitoring of the surface water as well aa the
eedimenta will ensure that no additional oou1.·cee exiet and that the
curren1.: problems. ai:a eradic\!-tltd.
ThB site groundwate~ waa charact~rlted by sampling and analyaie of 21
monitoring wellB whl.ah ·we,·a ineto.lled during the RI, Figure 7
provide a the monitoring v~ell loc'ations. Five raaidentidl well a were.
also sampled.
Volatile organic compounds, voes, in groundwater are of p1.·inciplo
conca1."n at the Jadoo-Hughes aite. Table· 5 identifie-e: the-twe-nty ftve
voes 1denti!iect in the gr.oundwatar, TwRl.vs of these compounds ex.caeid
drinking wate1.-criteria. These ar-e {in. de,;re(t..aing ordf.Jr of maximum
concentration) as follow81
o acetone
o chloroform
o vinyl chloride
o 2-butanone (alao kno~n as mothylethylkotone)
o carbon tetrachloride
o 1 1 2-dichlo~oethena
o methylene ohlor"ide
o 4-mathyl-2-pantanona (also known ae methyl-iaobutyl ·keton~)
o 1,2-diohloroethane
o benzene
o 1,1-dichloroethene
o trichloroathene
voe contamination ie moat prominent in the former operations area at
well 11W6S and the formsr south decant pit area at wells MW2D and
PWl. Groundwater contamination by VOCe is aleo evident at the
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following monitoring wells, MW3S, MW75, MW8s, o.ud MW5D, voco
present at theae wella a.re generally an order of magnitude lower than
contamination found in former source ~reae. TheBe e.1:eae of
contamination may be a.tt.ributed to unrecorded, isolated L-elaaeee over
tha eita.
The results analysis tor extractable or9anic compounda, aleo k11.own o.~
basa-neut.1:al-ac!.d compounds (BNAs), identified fourtaan BNA
ccmpour1d8, Table 6 identifies thssa compounds. Three of theee
con1.:amlnante exceeded drinking water ntandards, ,
o bie(2-chloroethyl}ether
o 1,2,4-trichlorob8nzftn~
o 1,4-dichloroben~ena
It must bB noted that drinking water criteria are not eatablial'l\ad for
many of tho BNAg,
The presence 6f BNA comflounde foll owe the pat:.t.e:1:n of pi:-ominent voca.
The BNA compounda of greateiat concent.L·ation ui:e found at mor1ito1.·ing
wells located in tha former operations area a.n.d the fo.r:me1..· south
ct .. oant pit.
The preeience of ino::ganic, or mata.1 conc.:entro.tions are often detectl'!ld
in groundwater eamples einca matalB e,·e naturally occurr l.ng element a
v.1ithin the st1.·uctu1.·e of an aquife:c. Twe:nty-on8 metals wsre detected
in groundwater samples and a1:e ehown in Table 7. comparia:on to
background concent.ca.tions, as well as fJ:equency of detection were
utilized in the selection of contaminant.a or concern. The
concentrations of eleven 'metala exceeded drinking wa.ter criteria,
0 · aluminum
0 antimony
0 arsenic
0 beryllium
0 cadmium
0 chromium
0 iron
0 lead
0 manganese
0 nickel
0 vanadium
Groundwater within the ehallow eaprolite is believed to discharge tc
the tributaries of Fites Creek whila tha deeper groundwater le
believed to mi9rata in a northerly direction. Groundwater migration
is estimated to move at a rate ot. approximately 8 to 14 per year.
Summyy of Bite Rieks
The following diaousai.on provides an qverview of the baseline public
health and environmental riek evaluation for the Jadco-Hughee eite.
It ie be.sec:\ on the "Superfund Riek Assessment for tha Jactco-Hughee
Site, North Belmont, North Carolina". The baseline evaluation helps
determine if a remedial aCtion is naceaaary at the site. It is
• •
dee:igned to reprasant an evaluation of the "no-action alternative11
,
in that it ic!entit ies the riek pr.,aent i! no remedio.l action i.a
taken. The bei.aeline asseeBmsnt a.lao providt,te the f1:amework for
developing the preliminary remec:l,l.ation goala for. the Jadco-Hugheo
site •. Field observations and analytical data ae presented in the RI
repot~t· represent exposure point concentratione for the risk
evaluation. Riek from the i'uture inge~tion of the groundwater ia thG
moat eignif icant rial< poeed by the a ite,. l'otentia.l impact on Hur.face
water 1.a aleo of. conc0rn at the Jadco-Hughea oi,.te.
The risk assesament for this daciaion docun1ent ia divided i.nto the
following components,
o contaml.no.nt identification
o Expo~ura aeeeeement
o Toxicity n..e:81111ement
o Ri•k Characteri~ation
contaminant Identific11tion
The objective of contaminant identification ia to •oreen the
information that is ave.il-able on ha.z:.ardoua eubatances or wo:~tea
present at the site and to tctentify contw:ninant.s of co1icern on which
to focus the riek assessment proceos. Contaminants of concei:n a.re
selected based on magnitude a.nd frequency of·occuri:anco, their
toxicological properties, and/or becaual!I they a.re p1.·eaently in or
potentially may mova into critic~l axpoei.u.-e pathwo.yl'! (e.g. r drinki:'lg
w"ter supply) •
The media of concern at the aite are surficia.l aoile, and sedimante
adjacent to the south decant pit and former operations area,
aubaurface soils in the north and. south decant pits, formai:
oper~tions area and onaitti landfill; gi:oundwater and ·eul:."fa.ce water in
Tributaries in A and B which flow into ~itea Cr&ek. contaminont~ of
cono9rn in the eubeurfac(j aoila and groundwater are volatile organic
compounda (VOCB), extractable organic compoundo and metals. l=!CBs are
the contatnina..nta of concern in the eurfoce soils and aedimente:. The
surface water contamina.nta of conce.r.n a.re the 9roundw~.t8r c:hemicala
which could discharge into tha Buz.·face water. Thu expoeut£e point
concentratione for eubeurt'aca soils ie boaed on the arithmetic mean
of the detected valuEH1. These mean concent?:atione are contained in
Table 8.
The eXposura point concentrations for groundwate~ fo~ the risk
deeeaement was based on tha three following mean concentL·atione:;
o mean of all detecte above a ample quancJ.tati.one limits ( SQLo)
(Level 3) 1
o rnaan of all detect~ above SQLa plue nondetecte aa~umed to be
present at ona-half the concentration of the SQL (Level 1);
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10 9st.h percentil m1:tan of the prec\='eding mean concenti:-~tion
(Level 2);
The sxpooure point concentrationa for groundwate~ a~a contained in
Table 9.
The exposure point concentrations of PC:Ba it'1 the sui.~face eoi.l!' and
aediments for Levels 1,2, and J are 90.6 mg/kg, 189.7 mg/kg and 107.0
mg/kg respectively,
Future surface water concentrations were ca.lcula.ted bt,.~ed on complota
discharge o! groundwater to the tributad.es and subaequent dilution
based on the tributary flow ~ate. Surface w~tar ~xposure point
concentrations arQ contained in Table 10.
Expoeure Aeeeeement
The objective• of an expoeure assesament are to identify actual or
potential axpoeure pati1waya, to characts1:lze the potenti.ally expot!ed
populationB, and to detBt·mina the extent of the expo&ure.
Identifying potan-i:ial expo·aure pat:hways helpe to co0ceptualize how
contaminants may migrate fi;om a. soui.-ce t.o ttn exinting or potential
point o'! contact~ An expoeure pathway may be viewed ae con&inting of
four elements: ( 1) A source and mechania1n or chemical release to the
environment1 (2) An environmental tntnepoi;t medium {e,g,, air_,
groundwater) ror the released chemical; (3) I\ point of potential
contact with the contaminated medium (referred to a" the exposure
point) 1 and (4) l\n exposure routs (e.g., inhalation, inge~tion) at
the expoaura point.
The expoeure o.eaesarnent for the. Jadco ... Hughe.e i,i.t.et evaluat&d the
potentia.l expoe:ure pathways of air, Burface wateti:, e:oi.l, o.nd
groundw11ter.
Potentially complete axpoaura pathways include;
o direct contact with conta.minate:d a:urface eoil 1
o future uae of conta.mlnated groundwater o.ri1 a drinking watar
eouroe1
o future recreational use of contaminated surface wo.teet and
o !utura contact with contaminated eubeurfaoe noil due to
conetruction activitiee oneite.
Potential exposure is .characterized by ths loc11l setting. The eite
.la vacant. and partially aecured by a fence. Human o.cC9'!HI to the aite
is int'.t"equsnt and unauthorized. Tributa.riea A and B are s1nall
r:,treams which flow adjacsnt. to and converge downat1.·ea..m of the, eit-a,
surfe.ce water ia not used as a. drinking water supply 01.· for fishing
in the vicinity o! the aite. Grounawater ia not used as a drinking
water iauppl.y onaite but ie a water eupply resource offaite for
residents having operational wells installed prior to the provision
of municipal water connections. Table• 8, 9, and 10 provide the
contarninante of concern in each medium.
•
Toxicity As~eaament
Toxicity aasessmant, as part of the Superfund baeellno riBk
aeeeaament proceaa, considers ( l) the typee of adverse heal th or
environmental sffscts aeeociated with individual and multipl"
chemical exposures/ .(2) the relatio11ahip bBtw&<m magnitude of
ax.posuree and adveree ett'scta, and (3) related uncertainties a}lch ae
t.he weight of avidancei for a chemical's potential cax:-cir109enicit.y in
humane.
Ripk Qhpro9tari£ation
In tha :final componant of the riak asseaernen.t proceea, a.
characterization of the potential riake or advo~ae health o~
environmental effects foi: each of the exposure acenarioa derived in
the exposure assessment, ie dev~lopod_ and summai:-ized, Eetimatas of
riaka are obtained by integrating information developed during· the
exposure and toxicity aaaeeements to chai:actet:"i:z.e the potential or
actual r·isk, including cai::-c inoganic '!:ieke, noncarcinogenic r ieks, and
environmental risks. The final analysis includes a summary of the
riaka associated with a sits including each projected exposure route
tor contarninante of concern and the distribution of 1:iske aci:oee
various e$ctore of ths -population.
For noncaroinogenic chemicals, the pr&dicted axpoaure level is
compared with o.n EPA reiference level or raforenoe dof:'e (RfO), The
R!D ·i• baaed on an eva.luation of current toxicity data and ia the
lifetime dose which io likely to bs without significant risk to human
populationfj, An exposure level which exceeds the RfD io an
indication that there may ba a concern for a potential.
non(?arcino9enic health 1:iak.
The carcinogenic risk levels are Erobabilitisa that are expressed
scisn,tific notaiion (e.9. l x 10-) • An exoe"~ lifetime, cancer
r iek of 1 x 10-indicates that an individual has a one in a
in
million cl~ance of developing cancer as a result of eite-relatcd
expoaur~ to a carcinogen ovar a 70-yeai: lifetime undar the epecifio
expoe,ure conditions at t.h.e site. The exceee cancer riek levelPJ o.re
up~erbound eatimat.ae which meana that the i:isk leveale a,:e probably an
overestimation o! the actual cancer risk poeed by the ~ite-relatad
pathways. Th0 EPA acceptable risk range ia l x 10-4 to 1 x 10-6
or ona in ten thousand to one in a million, Although a riak range i~
designated, EPA uaea 1 x 10-6 ae the poi11t of d"'parture indicating
that the preference is for set.ting cleanup goa.le: at the moJ:e
protective end of the range, The cleanup goal of 1 >< 10-6 may be
rovised to a_different riek level within the accaptable range baaed
on the coneidei;o.tion of appi:opri.a.te l!it~-rolatod factore,
The current risk posed by onsite eurficial soils contaminated by PCBa
was evaluated. This risk is associated wl.th potential contact with
soil by people who have gained unauthorized site access and resulted
in a calculated ri.ak level ranging from 7 >< 10-6 to l x 10-4 .
•.;.•J -1
• •
current uas·of rasidential wells located immediately downgi:-o.dient of
the eite was avaiuated. The aaeeasmsnt identifi.,d tliat: compound~
deteCted in potential reaidential water eupp1iss were balow ·drinking
water criteria or standards. As such, tlH:ls8 det.scted compound!! do
not pose a current unacceptable risk to local i:eeidenta.
The future potential riek associated with offsite groundwater use ae
a drinking water supply wt1s evaluated. Under thie Bceinario a
contaminant plume ia assume.id to migrate, unremsdiatod, offsite' and
result in increased contaminant levsla in resid,ential w"lls. 'l'he
ase~cia.ted pot8ntial additional lifetime cancer i:ie:k l·e\.ngad from 6 x
10-to· 2 x 10 and the noncarcinogenic 0x.posu1.·e levele exceeded
tha reference level. These values Bxceed acceptable riBk levels.
The potential future ri9k du~ to axposure to conta.min~ted RUbBurface
soil one1te waa evaluata<l fo~ a construction worker involved in~
hypothetical .excavation activity. Th"' potential additional lifetime
cancer risk ranged from 5 x 10 -lO to 2 x 10-7 • These levelo are
below the acceptable ri!:5k range. The noncai;cinogenio expoeure levels
were alao below t.ha EPA l:efeiL·ence levftl.
The tuture potential riak associated with an offsite 8xpoeur~ to
contaminated surtace water wa6 evaluated. Un<leL· thie acenai:io a.
contaminant groundwater plume would discharge, unremediated, to
surface water resulting in increased cont~minant level!t in esurfa.ce
water and subsequently creatinQ a potential i:-ecl.·eational expoeuro.
'l'he aaeociated potential additional 1.lfet.i.tne cancer L"iek ranged from
9 x 10 -7 to 3 x 10 -S. The noncai:cinogerdc: ,e1xp0Bu2:e laivele did
not &xcaad. the, L"efeL·ence level!!.
The baseline rial< aeeaoemant indice.tea \:hat t:h<> gc·eateat potentio.l
risk trom the J~dco-Hughaa sit& ia vi~·ingeation of contaminated
groundwater, Although, exposure to uneafa levels ot contaminated
groundwater iB not presently occuring, further movement of the
groundwater plume could cause offaite wells to be contaminated with
unaccaptabls levels of eite contaminants . .An altei:nate water esupply
has been made· availabl.0 to potentially affected resl.d0nts. In
addition, potential rieks trom axposura to cont13tnirH:\ted groun<lwatei::
and other media are being addreeaed ln thie decieion document.
Doacriptionu of AlternativeR
The RI r0eulted in the following definition ot the nature <1nd extent
of contamination at the Jadco-Hughee "ite.
o contamination or no less that 6000 yd3 of aubeurfaoe soil
;i?rincipally cont~inated with volat.ile oLganic compounda
(VOCs) and extrac,table organic compound a (.llNl\a) /
o contamination of groundwater beneath the site with voes,
8NAe and metala,
o contamination or Tributary a, predominantly by voes 1
0 contamination of no leas than 435 yd3 of ourface •oil -,ith
PCB concentrationa exceeding 10 mg/kg (ppm).
A total of 11 alternatives were evaluated in del:.aiL for 1.·em_ediating
ths site. Nine remedial alternatives address the contaminated
subsurface soils that oon~ribute to gro.undwater contamination. n:ight
alternativaa addreee: th_e contwninaticn in the 91:oundwatar beneath the
site. Each alternative presented easentially builds upon the ~cope
oft.he previous alternative.
Alteroativs l -NO A.ction with Monitoring
The superfund program require• that the "No-Action" alte,:r.ativ" be
conaidered at every eite. Under this alternative, EPA would take no
further act.ion to control. thB source of conta.rnination. P.cwover,
long-term monitoring of the site would be necaasary to monitor
contaminant migration.
The FS interpreted the "No-Action" alternative literally and aooumed
no. action whatsoever would be necaaaary. Aa pr~viouuly atatad,
monitoring would be reguired due to the resulting contaminant•
remaining onaite, rn_.i,uch cases, CERCLA i:equira• that the eite be
reviewed every five years. The "No-Action" altei:nativ" preaented
within thio deoieion documQnt was develop9d from specific coating
information !..d.entitied in the FS, baee<l on monitor~ng of 8lte
contamination on a quarterly baeie every yea~. Monitoring oAn be
implemented by using previously installed monitoa·ing wells and
reoidential wella.
If justified by the review, remedial actions would be implemented at
that time to rsmova or treat the wastea.
The present worth cost Ot this alternative for a 20-year pe~iod ia
approximately S890,000. The time to implement thia alternative ia
two months.
Alternative 2 Dead, Aooeee Resl;rictiona and Honi,to,;inq
Dead teatr1ction involves placing inetitutional controls on the uec
of the p.t'operty and the usa of· groundwater beneath the Site. f\.cc&aB
reatrictioo invo.lvee a security fence· to minimize una.uthorized
acceee. The fence ia to be constructed as an interim 1,.~emedy and
consiete of an 8-foot high·ohain link ranee and locking gates to
replace tha present tsnca. Th~ fence ·will be permanent 4nd is to be
eituated at the site perimeter, Monitoring involves o. perLodic
meaeuremant of groundwater and eurface water quality to asoan= any
changes and ta:ends of'. contamination.
Deed and accaae reetrictiona would not prevent furth&r migration of
groundwater contamination. Alternative 2 is deeigned to eliminate
exposure to contamination which ex:iete on eite,
The pi:aaant worth coat or this alternative io $947,900, Thie
alternative ctoBs not achieve ARARs, offare no protectivenees.
(Remedial actions performed under CERCLA must comply with all
applicable or.relevant and Cippropriate requi.rementa or ARARo. A more
•
complete dieouee1on on ARA.Rs -is prov~ded in the S'l.:atutory
oeteminationa Section of thi.a ctecinion doc'.lmaint.}
Altarnat i ve 3 cap, Deed and Acceae; Bastrictiona, Monito1.•in6:
Thie alternative addre·esea the soUY within the existing on-site
landfill with the provleiono of a RCAA cap designed to minimize
infiltration into contaminated eoile, Figure 8 provides a schematic
of the RCRA cap.Leaching of natural precipitation would be inhibited,
thereby reducing the s_ourae role to groundwater. Limited excavation
work would be neceeea~y for tha in8tallation of· a cap.
Alternative 3 builds ui;,on the scope of l\lternative 2, The
contaminated s~ila within the landfill ia eutimated to be no less
than 5,500 yda . l\pproximately 500 additional cubic yard• of
contaminated soil8 wou:ld be excavated frc,m the former ope1:atione area
and consolidated within the soila of that landfill prior to tho
installation of the RCRA cap.
This alternative does :not prevent fut:t.her migration of contarninatad
groundwater, Thia alt.ernative would eliminat.& potential onsito
contaminant expoaure1 .. monitoring would be conducted to track
contaminant migration, no provieion would be made for conta.rninant
reduction, l\lternative 3 would not achievs ARARe.
The preeent worth cost of this alternative ia approximat<>ly
$1,505,900, This alternative ia readily implementable,
Alternative 4 -cap, Groundwater Extraction, Treatment, Di8char.ge to
Fites creek, oaed/Acceee Raetrictiona, culve~t Replac~ment and
Monitoring
Alternative 4 buil,c!a upcm.l\lternative 3 by the addition of a
groundwater remedy and a surface water ramedy. Grouridwater
extraction would be accomplished by the uae or a aubaurface tile
drain ayetem to collect groundwater and would ·prevent future offsite
migration of cont~inated groundwater. The extracted g~oundwater
would be t~eated followed by dischar:ge to aui:face wat&l:'. Soi le
contamination would be add.reseed by a cap with no reduCtion of
contamination. Monitoring of tha contamination would be requl.r.-d.
Extraction wells would be located in the areas of hi9hast
contamination ooncantration anc! would be utilized roo· "hot apot"
pumping. The etteativsnmaa of the groundwateL~ rei,medy and the
progreea of remec!iation would be avaluated by monitorinq,
Groundwater:-treatment and discharge would be accomp).ished via a
pre-treatment to~ metals removal followed by ultraviolet oxidation
and discharge to ~ributary B, Monitoring of thia tributary would b.-
conduc:ted to ensure et't'ectiveneaa. The WO treatrnent teohnoloc;,y wo.a
selected due to ite ability t.o t.rsat thtt compounde of concern.
Figure 9 is an illuetration of the UVO treatment ayetem coupled with
the o~one pretreatment system for metals. Pre-treatment for meta.ls
removal would require d.ieposal of inorganic sludgee.
•
Ultra.violet oxidation l5 a relativel}' new technology which wae
evaluB.ted by a treat~bilit.y et.udy and offe1.-e the most p1:omiaing
t.echnolo9Y for achiavin9 the low level)j of. diochar-ge requ.i.red for
audace water discharge. The treatability otudy reeulte "re
atta.ached ae Appendix c. However, probleme aeaociated with natui:al
inorganic cherniet!:y of the groundwate:l; pie:l!lent pot&ntio.l Operational
problems when high efficiency treo.tment io requirec1. Sp,.cifl.ce.lly,
iron may preferentiall:f coneume the oxidant reault.in9 in o. reduc0d
efficiency in or9~nic treatment. Acco1.·din9ly, an ozone pretreatment
syatein comp;r:iaed. of a tank, C;JZ.one di(fuaet·s and a clarifie1: would be
required to condition the ·wa.te.r: prior to pL"oceBaing in the uvo
ayetem.
surface water remediation would b~ accompliehed, in part, by
groundwater extraction which would intercept. cont:.a.n,inat:.&d groundwatez:
~l:'ior to discharge to Trib~tariea A and B. The replaceni~r)t Of tha
onstte culvert· and the construction of a apillway would repi.-eeent the
remaining action neceeea.ry to pi:event contaminated groundwate1:
diecha;i;9e to Tributary B. Th~ culvert replacement. involves
eliplining the culvert.with HDPE pipe and plugging the annular apace
batwasn the old and nsw pipe and the pipe bedding. The HDPE pipe
would allow etreamt'low throuQh the sits. Contaminated groundwater
would not leak into the HDPE pipe and would be prevented from
migrati~n along ths old culvert and beddin_g material by the
installation of plugs~ The sxisting culvert could be ueed to augmer:t
groundwater collect~on thcough the uae of the annular 8pace a~ a
collQction trQnch.
The preeent worth coet ot thie alternative ie $5,344,900. Thie
alternativB would not achieve ARARs. Thie altarnativa could be
implemented within a 12 month pariod.
Alternative 5 -Soil Vapor Extracti□n, Soil Flushing, groundwater
Extraction, 1r8 atrnent and Diecharae to Fites creek, oeect
Reatrictione, Culvert Reolacoment and Honitorino
Thia alternativa le QeeBntially the earns a_e: Altarnativa 4 except· that
the cap is replaced by soil treatment. Alternative 5 utilized aoil
venting and eoil flushin9 to remove contaminants from eoil and
treatment of the off gae by carbon adeorption,
Soil venting involves the placement of parforatad,vents Vertically
into the contaminated soil above the water table., The extraction
vents aLe connected by aolid pipe to a common above-ground header. A
blow~r drawa a vacuum throu9h the pipe net.work allowin~ soil 9aB to
bs sxtractsd. Contaminants partition from the aoil to the air and
the oontaminat~d air etream ia treated by carbon adeorption. Figure
10 illuatratea the aoil vavor extraction (SVE) system layOut.
Soil fluahing would be conduct~d following the terrnin~tion of soil
venting and 18 designed to ren,ova soluble conta.rninant0 which are
non-volatile. The eoil fluehing system would involve controlled
infiltration of water into contaminated aoil, Uncontaminated water
from Tributary B would be used as a water supply. Thia water would
be pumped into the recharge ~yatem vi~ 4 common header. The recharge
•
aystem would be-dee:ign~d uuch that the rate of flow to each rechai:ge
well could bo coI'ltrollod,
Recharge water would contact contaminated E>Oil a.Bit infiltra.tee
downward. The effectivaneae of the 8yetern\ would be enhanced by
introducing rscharga watar in pulees and rotat.i.ng recharge
locations. This pro~ectu~e would create a ~atuLated wetting front
within the conta.minated eoil, thereby increaSing the partitioning of
contaminants from eoil to water. Cont.arninated 1.~echar9e water would
be captured by a groundwater drain eituat&d in~ downgradient, onaite
location and woulct be pumped into the eita'e groundwater treatm~nt
eyetem.
The remaining componen~s of Altarnative 5 ai~a the groundwater
ax.traction system, ozone pret.raatment for metals, UVO treatment and
diachargs to Tributary 6 aurfaca wataL, oulvert replacem~nt,
monit?r1n9, with deed and acceee i:eatrictions,
Alternative 5 elimina.tae pot;.ent:ial oneite contamiria.tion expo!mrai. It
providaa remedies for aoil and groundwater with contaminant
reduction. Monitoring wOuld. ba conducted to track effectiveness of
the remedy.
The present worth cost ot thie alternative ie $6,164,900, Thia
alternative would achieve I\RARe, It is estimated that tha RD and
installation of extraction wells could be completed within one year.
S011 venting would be completed in one to. three yaara, aoil fluehing
and groundwater would bs completed within 30 yeo.re ..
Alternative 6 -Off-site Land Dispoaal, Orogndwater m~traction,
Treatment and Discharge to Fite• creek, Dead Acceee Restriction,
Culvert Replacement and Monitoring
Alternative 6 involves the removal or approximately 6,000 yds3 of
contaminated eoil and replacement with olean eoil. contaminated soil
would be axc~vated and loaded onto truck8 for transport to a RCAA
permitted landfill.
Any-major excavation progrtlffi would require ab.~ monito1.•ing to anr,Ur.a
that orrsite air quality is not significantly i.mpaoted. Groun<.lwater
remedi~tion, deed and ~ccea~ restrictions, culve~t replacamant and
monitoring are identioal to the program identified in Alternative 4.
This selection eliminateo the potential onslta contaminant e>epoaura.
It contains~ provision of gi:oundwatal.' and aurface w-ater remedy with
oontaminant reduction. Soil remedy selection does not provide
contaminant rsduction. Monitoring is required of effectivene~s of
the remady.
The present worth of this remedy ls ~7,632,900, This remedy is
readily implementable. Thie alternative would meet remediation
goals, however, this alternative haa implementation con~erna with
respect to the regulatory deadlines for RCAA land disposal.
I) •
Alternative 7 -On-site Soil Iocinaration, Groundwater c,xtra.ction,
Treatment am~ Diecharge to Fitea Creek, Deed Acoesa Roatriction,
cuJ.yert Raplacement o.nd Monitoring ·
Alternative 7 involves excavation and treatment by onsite
incineration of approximately 6 1 000 yd3 of co1)tamin'ated soila from
the landfill and formar operations area. The 1:.raatment of the
contaminated soils ie conducted instead of the installation of a cap.
onaite incineration is a treH1.tment method for organic compounde which
uses hish teffiperature oxidation undBr cont2:olled condition!: to
degrade a substance into carbon ctiox.ide, water vapoi:-, sulfu};' di6xide,
nitrogen oxides, hydrogen chloride gaeea and ash, The hazardoue
products of incineration, _euch as ptu.'ticulatea, eulf\1l:" dio:x:idl!!!I,
nitrogen oxidee and hydrogen chloride req\\ire air emission control
"'I"iJ?m<>nt.
Alte::-nl;ltiva 7 propoeaa oneite 1.nci.1101:a.t.ion with the uee of a
Circulating Bad Combuet·or (CBC) 1 which is presented on Figui:o> ll,
The CBC incinerator uasa_temperatures in excess of 1500~ F. oneite
incineration typically achievea·greater than 99,99 percent ramoval of
organic contaminants. The contaminated soila would be excavated, fed
int.a the incinerator, treated and btlckfilled.
The remaining elenu~nta of groundwater remediation, de_ed/tt.ccers~
restrictione, culvert;. raplacemant and monitoring will utilize the
same methodologies as identitiea in Aitarnatives 4 1 ~ and 6. Thie
alternative eliminates potential on-eite contaminant ex.poeure, 'rha
alternative providee: a remedy which adc1reasea 9roundwate1.· surface
wate.r and soil contamination with r-eduction of contamination.
Monitoring is requi.r0d to track thA effectiveneea of the remectY.
'£he present worth of thie remedy ii, $3 1 8951 900. Thia remedy .i•
readily implementable, but would n□t achieve l'IR1'R8.
Alternative 8 .. cap, Groundwater Extraction, Treatment with Diachaige
to POTW, Deed and· AccBse Restriction6, culvert Replacement and
Monitoring
Alternative 8 is similar t□ Altarnt<tivi, 4 but offei:a a different
method of groundwater"treatment and discharge. The gi=oundwater
extraction aye:tan.1 remains th·a aama and conaiete of downgradien·t
control and hot epot pumping. aowavar-, Alternative B involves
dischargirig treat~d wat~r to the·Belm~nt PO~W through ths eewer
Byetem. Aeration wae det~rminect to be the most coet-etfective method
of treatment i:equired to meet diechai:ge i:equiremente to a POTW,
Aeration oneite involvee the construction of an in-gi:ound o.eration
basin having a volume of 9,000 gallons. Air ia eparged into the tank
by diffusers to ,:educe voe concentrationa. The ah· would be vented
through a carbon adsorption eyetem to restrict voe releaeea to the
atmospheree.
• •
Water discharged 'to the Belmont POTW would be further treated there
by biological degradation and aeration. The FS conc·111ded that the
Belmont aewage t,:Q13.tment plant can affectively treat water diech11rged
from the Jadco-Hughea site,
AHernative 8 aleo include• eoil remecliation by the installation of "
RCRA cap, The low permeability cap inclt1d0s a synthetic lini,r to
mitigate future relsaeee of·VOCe from contaminated soil, theraby
elirnina.ting the source of groundwatei: contamination. An in aitu
treatment of soils is provided by Alternative 8. Peed reatriction
and accee.s restriction componei-,te: do not: change f::Ol\\ th~ prftvioue
alternatives.
Thio alternative elirninatea potential. on-site contamina.nt exposure.
Thie alternative providee a remedy for. gi:oundwo.ter and eurface water
with reduction of contamination. Tl\e ~emedy selection for eoil doeo
not provi~e contaminant reduction, Monitoring ie required to track
the effectiveness of th.a rem~dy.
The present worth of thi• remQdy ie $3,895 1900, This alte.native ia
readily imFlementable,·but does not achieve ARARe.
Alternative 9 -Soil Vapor Extrac:tion, Soil Fluehing,___Q_f_oundwo.ter
Extration, Treatment ai1d Discharge to POTW, oeect and Accai!JB
Reatrictiona, Culvert Repla6ement, and Monitoring
lllternative 9 provides aoil remediation by Boil venting using"
eeriea of vertical vents installed into the tl\e contaminated Boil
above the water table. Under a vacuum, VOCe and some BNAe ~re drawn
into the air at.ream and are aubeequently removed by carbon
a.deorption. Thia prooeelii would be complete in thrae yaara of
operation.
Soil fluehin9 is achieved through the introduction of uncontaminated
water through the eoil venting well• !ollowing completion of the soil
·venting treatment:.. Th& recharged water would be collected and
treated in the groundwater trea.tment 11yet&m.
Groundwater remediation ia accomplished by downgra.dient ext.i:action
and hot spot pumping using the extractio1~ ayeit.em aa dascribed in
Alternative 8. Groundwater treatment involves aeration to reduce voe
concentration• for acceptable discharge to Belmont's POTW. The ~i.
vented tram the aeration basin would be treated by carbon
adsorption, Additional treo.tment by biological. degradation and
aeration ie provided: es.t the sswage treatment plant.·
Remaining elemQntu of Alternative 9 involve dead and acceae
rest~iction, culvert raplacement and monitoring as dascribad in
previoue alternft:tival!!I;
Thia alternative eliminatee potential on-eite contaminant oxposure.
Tha ~emedy providae reduction of contamination in eoil~, g~oundwatftr.
and surface.water, Monitoring i~ required to track the effaotivenes~
of the ramedy.
•
The presa-nt worth of this remedy is $4,715,900. The l:"emedy la
roadily implementable and would achLeve ARARs.
ill~rnative 10 -Off-Bite Land oiapo~a1, Groundwater Extraction,
Treatment and Pischaras:t to POTW, Dasd and Acceaa Reatrictione:,
Culve~t ReplacemBn't and Monitoring
Alternative 10 involves the removal of approKimataly 6,000 yd3 of
contaminated soil. contaminated soil would be ·aKcavated and loaded
onto truck.a for transport to a IICRA permitted landfill. During the
excavation ;proceaa VOCB would be released to the atmoaFhe1.·e due to
volatilization. Air monitoring would be required to ensure that the
off site ah· quality i• not significantly impacted.
Groundwater remediation would be accomplishsd by downgradient
axtraction and hot epot pumping ur,ing the extraction system an
preaentE"ld in in Alternativee 8 and 9. Groundwater treatment would
involve a.0ration to reduce voe concentrations followed by carbon
adsorption for acc~ptable dieoharge to the local POTW
This alternative eliminates ~otantial on-eite contaminant expoe:ure.
The remedy provides reduction of contamination in surface water and
groundwater. No reduction of contamination is conducted in the
remedy selection for soils. Monitoring is required to track the
affBctiveneao of tha remedy.
The present worth of this remedy is $6 1 183 1 900, The remedy is
readily implementable.
Alternative il -On site S0 il Incineration, Groundwater ExtractiOon,
Treatment and Discharge to POT~, Deed and hcceqs Reetrictione,
Culvert Repla.cen\ent and Monitoring
Alternative 11 involve excavation an<.I treatment by on-site
inciner~tor of an·oatimated 6,000 yct3 of contaminated soils from
the landfill and former operations area, On-site inciner,ition
involves oxidation of organic compounda at tempeL·a.tu1tee 9reate1.~ than
1500 11 1-'. On-site incineration typically achieves greater than 99.99
percent removal of organic contaminante.
Remaining remedial componante of groundwater extraction, treatment
via aeration and carbon desorption, discharge to POTW, deed and
aocesa rsatriotion, culvert replaoament and monitoring are identical
to Alternatives 8 1 9 and 10.
On-site incineration requirea permitting of the incinerator and could
prasant a ai9nificant obataols to the implementation of thie
~lternativa~ Lack of community support could also present a
significant problem.
•
•
The present worth of this remedy is $8,305 1 9D0. Th■ remedy ia
readily implementable and would achieva hRAR6. Mods.rate concti:n:n
exists with 1:eepect to potential volatile org&.nic emi.sslone 1.4 eleased
during e~cavation.
summary of COffiparative Analveie
The major objective of the Feaeibility Study (FS) was to develop,
screen, and evaluate a~tarnativas fot· remediat.i.ng the Jadco~Hughea
eite. Thie decision <locume,nt deals with the groundwater, t.he eioila,
and surface water for which saveral alternativee wera idantifi~d.
'rhe technologies reviewed we1.4 e acre.erned basad on their feao_ibility
given the contaminants preaent and the aite charocterietice. Those
which remained attaJ:" tha initial screening were evaluated in detail
based on the nine selection criteria i:equired by SIIR/\ and liet,;,d in
t.he NCP, which c.re liated below;
OVeral.l Protection of Hwtleu'L Health and the Envlronmant.
addreeeee whether .or not a.'n alternative providel!I adequate
prOtection and ctascribee how rieke a.re elimini:!l.ted, 1.·aduced or
controlled through treatmant and engineering or institutional
controle:,
Cqmpliance with Applicable or Relevant lllld Appropriate
Requiremente (ARARe) addreaaea whether or not an alcernative
will meet all of the applioabla oa· relev<>nt and appi:opi:iate
reguiremente or provide {Jrounds !or invokin9 a waiver.
tong-term Kffectiveneas and Permanence refere to tha ability of
an alternative to maintain reliable protection of human health
and the environment, ove~ time, once cl~anup objectiveo have been
met.
Reduction of Toxicity, Mobility or Volwna is the anticipatod
perfoi:manoe of the.ti:eatment technologies an alternative may
employ.
Short-term Effectiveness involves the period of time needed to
achieve protection and any adve1:ae impacte on human he-ilth t'lnd
the envit"onment th~t may be poaed during the conatruction and
implen,entation period until cle~nup objective" ara achieved •
Implementability is the technical and aclminiatrativo
feasibility of an alternative, including the av,ailability of
goods and services needed to implement the solution.
coet include~ capital co~te, as well ae ope~~tion and maintenance co~t~.
A9oncy AocoptlU1oe indicates whether, based on ito review of the technical
documents for all aspsate of tha Site inveatigation, and the Propocied Plan,
the U.S. EPA and the Tennessee Department of Health and Environment (TDHE)
agree on the pi:efet're-d alternative.·.
Coiamunity Acceptance indicates the public support of a given alternative.
Thia orit_aria is discus sad in the Responsivensse Summary.
•
It ahould be noted that cost ie uoed to compare alternatives only when they
provided similar. degrees of protection and treo.tment. Three alternativee
rama1nect attar the detailed evaluation; llowever, ~11 elevan altarnativeo
preaented in the FS are evaluated below. A eummary·of the relative pe~formnnce of
the alternativee with reepect to each of the nine critel.:io. il'J Provided in this
section.
Proteotivenese of Human ijealtl) and the Environment
Alternatives 4 through ll prei,entad in this document would be
protective of human health and the environment, Alternatives l, 2
and 3 are not protective of human health or the environment. Theee
three alternatives allovJ further migration of the contaminan,t8,
leadin9 to poeeibl<> ingestion of contaminatad water if drinking-water
wella were to be used for potable purpoeee.
compliance with Applicable or Relevant and App1.~opriate ReguirarnsntB
( hl\l\RB)
several of the alternatives identified in the FS would not comply
with applicable or relev.ant and appropriate requirements (AAJ\Ra).
Tho no action alternative would not addreaa the groundwater
contamination and would allow the contaminants to remain in ttie
groundwater at concentrationa o..bove drinking wate:r et.andardn, thue,
violating the sate Drinking WatBr Act (SOWA), which ie a federal ARAR
for this aite.
Reduction or Ioxicity, ·Mobility, or VolumB
Remedies that uae treatment to reduce the mobl).ity, toxi.oity or
volume (MTV) of the contaminants at a aito o..re preferred over those
remedies that do not, The eleven altarna.tivea presented in the J:S
ware evaluated under this criterion. Alternatives 1, 2, and 3 maka
no attempt to reduce t~a MTV of site contamin~tion. Alternativee 4,
6, 8~ and 10 offer MTV reduction o! 9roundwatar contamin~tion only.
Contaminated eo·ile a1.~e addreased in varying methods, including no
action, containma,nt or off-aito diBpoaal. Alternativas s, 7, 9 and
11 o!far the reduction of MTV for groundwater contru:ni~)at:.lon and soil
contamination.
Long-Teim Effectiveness and Permanence
The majority ot the alternatives preeented in the FS would have
lon<J-te:r:m effectiveneea and permanence One-, clean-up goale. a're met.
Al ternativei, 4 through 11 addreaa the conto.miclailt plume in the
groundwater with similar daei9ns of .tha extL·action eyetem but wlth
differing treatment t0chnoJ.ogies d&psndent upon fin"-1 discharge
point. Alternativee 1, 21 and 3 do not ofrar permanent remadiea for
any of the contaminated media preeent at. tha site.
short-Term Effectiyeneee
•
The eleven al.ternativss wBre evaluated with raspec.;t to ahort-term
affectiveneSl5. Alt~rnativee 1, 2, and 3 provi<ie no p.rotectivonesn to
human health and the environment, and subaeguently tha fi1:et three
alternativ9a offlilr no Bhort-term afCt:,ot.ivaneee·. short-tt'!lrm
effectiveness is believed to be administered by the implementation of
l\lternativee 4, 51 8 1 and 9 with mini,~al problerna, l\lte,·natives o
and 10 provide-ahort-term affectivenoae, but also introduce
coneidarationa concerning the hazards aaaoclat&d with the axea:yation
of soils, Altarnativea 7 and 11 tt.180 in.cluda axoavation· concerns 1u1
well aa emiesions control, and residual waate ~~ncorns. The
implementation of a site epecific hsalt.h and safety plan would
mi,;igate the hazarde rl:om exoava.tion wo1·K. Engino:ering within the
Remedial Deeign plans would addrase emiaeione fl.~Om inc:ineration.
The short-term etffactiveneas of an ~lterna.tive a.loo includes
conaideri:1.tion of the time reCJuired for each.alternative to achieve
protection, The follo~in9 information ia provided for those
alternatives that do 1;)l:ovi:de short-term effectiveneaa,
Alternative 4 1 year cap 1.netallat.ion, addreaeea aoils
l\lternative 5 3 yeara for intitial eoile treatment
l\lternative 6 1.5 years for intitial eoile treatrnsnt
l\lternative 7 2 years for intitial aoils treatment
Altlirnative 8 2 year• for intitial aoila treatment
Alternative 9 3 ·yoare for intitial eoils treat~ent
Alternative 10 1,5 years for intitial soil• treatment
Alternative 11 2 years tor intitial soils treatment
l\lternativea 4 through 11 estimate that the sroundwater water remedy
will achieve groundwater cleanup goals within 30 years,
Implementabilitv
The implementability of an alte1.4 native ie bal!led on technical
feasibility, administrative feasibility c,nd the availability or
servicee and materials. Sarvicea and. matei.·ie.l~ are available for all
alternativeB. Dua to soil vapor extraation being an innovative
technology, there ie limited. demonstration data av~ilable. Faotore
at the Jadc::o-Hug-hsa aite, auch aa depth of eoil contruninat.ion and
eit.e of soil contruuination araa.s whe1.~e considered in the development
of the various technolo9ies. Additional concerns included Land
Disposal Restrictions in thos~ alternatives were off-eite disposal
was considered. Concerns such aa emissions were considered under the
short-term effBctiveneea criterion .
.QQil
A present worth coat for the eleven alternativea preeanted for the
Jadco-Hughea aite are presented below.
Alternative l $ 890,000 (No Action)
l\lternative 2 $ 947,900
l\lternative 3 $1,505,900
Alternative 4 $5,344,900
Alterl'lative 5 $6 1 279 1 900
e
Altarna.tive
Altei:riative
Alternative
Al teL·native
Alternative
Alternative
6
7
a
9
10
11
--
$7,632,900
$9,754,900
$3,695,900
$4,830,900_
$6,183,900
$8,305,900
•
More detailed information on the coetin~ tor each alternative ie
pre8ented in Appendix D,
State AcoaptancB
The State of North Carolina, as rep~esentsct by tha North Carolina
Department o! Environmental Health and Natural Resourcea, NC-DEliNR iB
in favor of the· eoil vapor extraction, aoil flushing, groundwater
ex:t2.·action llnd treatment via aeu:ation, culvert ropla_cement, eurface
water diversion and monitoi:ing. The State will concur with the
discharge of the tr~at8d water to the City of Belmont POTW or other
local POTW for further treatment if the POTW ia willing to accept the
waato.
In the event the-city doea not a.ccept the ti:-eated 91:oundwate1:
effluent, NC-DEHNR oonoura with EPA'e contingency alternative of
groundwater extraction and t~eatmant by aeration, precipitation,
filtration, and carbon adeorption follow~d by eurfaca water
diechar9e.
community Acceptance
Bo.l!led on commente made by citizens at the public meetin9 held on Vul:r
26 1 1990, and those received during tho public commant period, the
co~unity agre&i, that an extraction and traatment aystem foz: the
groundwater, ae well· ae · the aoil vapo1: axtraction/soll. flushing
technologiee aalacted for soils are neoeaaary for effectively
protecting human health and the environment. Citizena did make
concl'!lrted etatemente regai:-ding thei~ desire for EPA to not allow
incineration.
Tbg Selected Remedy
Ba8ed on available dato. and analyaia to ddt&; tl\e US EPA haa proposed
Alternative 9 for the remedy selection ror the Jaclco-Hughee Bite.
The comparieon ot remedial alternative• conducted in the FS provided
tha basis of t.hia selection a.nd a.re preaentad in this decision
document.
Alternative 9 involves dead and accc,r,B raatrictions, soil ventin9
with carbon adaorption of tha off gaa, aoil flushing, culvert
replacement, 3urface water diversion, monito1:ing, gt·oundwatai.·
extraction and treatment by" aeration and vapor phdaa carbon
adeorption on site, discharge to tlie city of Belmont POTW or other
local POTW. How~yer, in the event that a POTW ha6 not agreed to
accept: the discharge fs·om th" Jadco-Hughee aite within a reasonable
period of time after t:he date of signature or the Record of Decision,
EPA haa eelectad Alternative 5 aa a contingency alternative.
I) •
Alternative 5, ccneists of groundwater extraction and treatment by
ozone pi:-e-treatrn8nt for metals followed by ultraviolet oxidation
(UVO) for removal of VOCa. Effluent discharge would be to Tributary
a. Both the aelectect and contingency alternativ~,. inolude
institutione1.l controls .or other land uae 1·eatrictioni, neceeeary to
prevent b.dveree ef£:eott1 to the remedy.
A_lternative 9. wae developed tor traatmo:nt of con:,tituante i:ecove1.·act
in groundwater to levels suitable for dischas'ga to a POTW. Tn"
proposed groundwater recovery system will includ9 in6tallation of
recovery wells in areaa of known high contaminant levell!I. Tho
anticipated flow rate ia estimated to be 1 gpm per well. Furtner
delineation of the plume will be neceaaary to dst.:armine the exact
location of extraction wells. The installation of bedrock walla may
also be necessary.
Recovered· groundwater wiil bs piped to an on-site treatment eyatem.
The actual treatment system will be baaed on the final diecharg<>
option. For t\.ltarne.tive 9, the S}'Stern would conaiet of t\n e.e~ation
basin with an equalization tank. Air diffuBion would be conducted
to provide a high rate air-to-water ratio. The air vented f1.~om the
aeration basin would be treated by carbon adsorption. The effluent
would be tested to verify that pre-treatment .etandarda are met. The
effluent trom the traatrnant eyatem would b8 pumped' to·thai naareat
City o! Belmont sewer i,y~tem manhole, The diacharge would then b<>
transported, via tne sanitary sewer, to the J>O'rW whare it would
undergo biologicai tr8atmsnt.
Implementation of the treatment and diechaL·ge acena.rio proposed for
Alternative 9 would require the responsible parties to ae:cu1:e th~
approval of adminietiative pereonnel from the cit~ govei:nment. of
Belmont. Ths treatsd affluent would have to meet pretreatm .. nt
criteria. established b:( thaee administL'ativa officiale as well ""
comply witn EPA guidelines for discharging o! a CERCLh wastewater to
a POTW,
Eaaemanta and rights-of-way would ba raguired for inatallation of the
recovat.·y welle and piping and the diechaitge piping to thtt ettwer
interconnection. TheeQ· &asa,me-,nta and i:lqhte:-of-way are ttas<1ntial to
the implementation of any remedial action.
Tne O&M will include monitoring of eyatom controls which will be
incorporated to ensure the effluent quality meats established
pretreatment criteria prior to discharge to the POTW. The routine
O&M procedure will reg:uira monitoring perfo1.~mance of the recovery,
aa::-ation, and diachtu:ge eyetem component8 a,, we,ll as periodic
cleaning or 1:aplaoement of the pa.eking media ae well tt8 the overall
aystem maintenance. Periodic manJ..t.oring of the groundwater will be
performed to aei:,ure that the remedy ie working, Detailed coat
analysis tor Alternative 9 is contained in Appendix D,
Alternative 5, the contingency alternative, .ie proposed in t.:ha event
that the POTW is unable to accept .the effluent from the Jadco-Hughee
aite. The primary-differencaa between the J?referi:-ed Reinedial
Alternative 9 and this contingency Remedial Alternative 5 are
I
•
twofold. lfh'Bt, 'Alternative 9 involvas discharge to Lhe POTW wheraae
Alcernative 5 dieich-arga8 tO surface water, second,-additional or
different treatment is nec.ee:aary to msst au.L"face wat~r discharge_
criteria, Treatment by ultraviolet oxidation involves the
construction of a.n onuite TJVO tret\tm0nt plant. WO ia a form of
chemic~l oxidation, Hydrogen peroxide and ozone (OJ) ni:e th9
con\nlOn oxidants used fO(' groundwater traatrnant, The oxidant. lf!I
bubbled through the waetewatei: while it is exposed to ultraviolet
li9ht. 1'he high en erg¥ ul tra..violet ra.diat ion caue00 theae oxidants
to form .hydroxyl i:adicale which oxidi_za the chemical conl:aminante in
the wastewaLer l1VO end producte are water, carbon -dioxide,
hydrochloric acid ( i"n emall a.mount a) and IllEttal oxldes. Ino.L~ganic
compounds will bB pratrea.ted prior to tceat.inent or the 01.-ganic
conetituenta by UVO. An inorganic aludga requiring diapoeal would
l:eeult from this pretreatment.
Traatability atuctiea will bs conducted during the development of the
Remedial Design to ~nsure the 1:1ucceeaful operation ae well as t.he
reliability of the treatment system. Treatability studies will be
conducted for the aelected remedy or aa well ae the contingenoy
remedy, if th<:' conti_nQenoy remedy becomae neceel'!lary.
The eftluant :t'~om the treatment eyet.em w.l.1.1 be tranapo1-ted via ti.
gravity pipeline to the selected diachai:ge point in Tribu\:ary B. A
NPDES ctiaoharge pennit may be rec;uired which will include the,
monitoring program to ensure compliance with surface water diecheu:ge
criteria. All NPDES subatant~ve requirements will be met.
As in Alternative 9,. O&M req\lirement for Alternl!l.tive 5 would includ&
inap0ction of the perf~rmanoe of recovery, treatment, and discharge
eyatem components and pariodio cleo.ning or i:eplo.cement of o.ny
naceaeary equipment. Additional O&M required for Alternative 5 would
include the collected and stabilization of eludgtn1 generated during
metals Ji,1.t.·e-t.reatmant. The caL·bon adeo~ption eyetsm would require
periodic replacemant. A detailsd coat breakdowli foi: l',lt&rnatl.ve S ia
contained in Table 13, Upon dsvsopmant of the Remedial Design,
further review·of any l\RARB applicable in tho management of i:eaidual
waatea will be identified and complied with, i.e. aludga, carbon
filtarii, ato.
Upon initial and tentative completion of t:he groundwater remec\J.ation,
the O&M re'l"irem,mt after ahut down of extraction walls will require
monitoring· ot the Qrou~dwater on a aemi-annual baaia. After final
remediation of grounctW~tar at the Jadco-HugheB site, o. re-evaluation
of monitoring raquiranienta will be conducted.
Under both thQ selected and contin9ency alternatives, groundwater
monitoi:ing would be performed to aeeeee tMe efficiency of the
recovery syatem. A.rio.lytica.l resulte would be uei:ed to track the
vrograee in achiavamant of the remediation goals,
Soil treatment ie th0 earne tor both tha. selected alter.·nativa and the
contingency alternative. Soil treatment ie via a vacuum extraction
process followed by soil flushing, The .vacuum exti:action procasa i•,
a technique for the removnl and venting of VOCs and some
I) •
semi-volatiles from ths unsaturated zone. Thla t.0chnolo9y would
involve the inBtllllation or extraction vents above the wate.t: tab~e
within the contaminated. eoil similar to the conventional met.hod. of
landfill gas extraction. A vacuum ayatam lnduces air flow through
the soil, stripping arnl volatilizing the voca from the eoil matrix
into the air at.ream. Wat.er in the air etream condense-a, ie separated
from the air stream and ie transferred to the gL·oundwater t.i:e~tment
Byatam. The contcunitiate:d air etream woulcf than flow through two
activated carbon unit~ ar~~ngad tn a ~~ri~a. Clean water ia then
introduced into· the contaminated soil ~one moving with the natural
<Jroundwatet' flow to be oo~lected within the ground\ifater collection
ayetem foi:-treatmsnt, thereby enhancing the eoil cleanup by a
flushing mechaniam, The soil contamination at th8 Jadco-Hughee aite
haa baan found to be largely organic in nature, o..nd. t.ha major portion
of the cont.amination was d61termined to be volatile.
A security fence ie being installed under the Interim Action Soil
Removal Program and is being placed along the perimeter or the
property boundary, ThiB will restrict unauthorized acceaa to tht!
eite ae well ae to the treatment area ultimat~ly minimizing the
potential for direct hu~an contact with any re!lidual contaminatsd
medi& at the aita.
The current !low ot water trom the e~ring, located to the east of the
site, accroe:a the forme1: operations a1:ea will be redi_,:ected a!I r,art
of the final remedy of the aite. Thie in neceeeary because of the
potential for conta.mination to be introducsd to tha tributary eyetem
since the former ·opera~iono area will continue to be a eource a~e~
until remediation is complete. The spring water is uncontaminated
prior to entering the aite ..
The goal or this remedial action is to restore groundwater to its
beneficial uae, which ie, at thie eite, a potential drinking water
aouroe, Therefore, groundwatei~ remediation will be pe1.~fo1:med until
all contaminated water meets cleanup goale throughout the plume
area(s). The groundwater cleanup goale are presented in Table 111
eoil cleanup goale are identified in Table 12, Both the groundwater
and 80il cl~anup goals a~a developed fo~ the claanup and overall
protection of the groundwater. Groundwater cleanup go~le were
derived from one of the following refe~encea,
o Reterence Doee (RfD) ie the systemic threshold
concentrations calculated for the protection of human
haalth, (Sam furthor oxplanation on Table 11);
o North Carolina Groundwater Regulations,
o For thoee groundwater atandards promulgated by the State of
North Carolina that ars balow analytical datect~on limits,
the cleanui;, goals were estabiiahed at the c,,>ntract Requii:ed
Quantification Limit (C.RQL) specified by the Contract
Laboratory Program (CtP) utilized oy the USEPA,
•
o Propoaed Maximu,m contaminant Lave la (PHCL}, t'1:opoe;ed
Secondary Maximum Contaminant Levela (PSMCL), and the
ProFoeed Maximum Contaminant Level Goals (PMCLO) ara used
when the l?'CML ia rno1.·a · cone&rva.tive and therefore more
protective of human health an6 the environment,
o The Carcinog~nic slope FActor, (CSF) ie Uf!ed to determine
the "one-in-a ... million" it1cre,mental lifetime canc:er risk and
to eatablieh ·a health baaed nurnbe1: foi: the p.rotectio'n of
human health
o The cleanuv 9oal eutabliahed for lead in groundwater waa
obtained from correepondan~o fron:i the D~rectoi.~e of. tha
Office of Emergency and Remedial Response and Office of
waate Programa Enforcement, USE?A, June 21, 1990 aa the
Recommended Cleanup Goal for lead at SupeL·fund eites.
Table 12 identifies specific cleanup goals for thirtaan soil
contaminunta, The final cle'1nup goals for the remaining soil
contaminanta at the Jadco-Hughes site will be developed during
pre-design work and will be based on site specifc data. ~artition
coefficients must be derived from eite specific soil column teata.
soil cleanup numbers will be designed to eneure that the remaining
leachability of the aoil oontamin.,tion will not exceed the
groundw~ter cleanup 9oals upon final remediation,
lt may become apparent, during implementation or operation of the
gro'undwater extraction system and ite modifications, that contaminant
levela have ceased to decline: and are i-ermaining constant .at levele
high<>r than the remadi'1tion go'1l over ~ome portion of the
aontarninated plume. In auoh a caee, the syetem performance standards
and/or the remedy may be. reevaluated,
The eelectad 01.~. oontin9ancy 1:e:medy will include 9roundwate1.·
extraction for an eBtimated period or 30 years, during which the
Byatam'a performanc~ will ba carefully monitorad on a ~egula~ baele
and adjue:ted ae warrant.ad by the performance data collected during
operation. Modificatione may include,
a)
b)
c)
d)
altarnatin9 pumping at welle to eliminate eta9nation
points,
pule& pumping to al.low aquifer aquilibro.tion and to
allow adeorbed contaminant• to partition into
11roundwater1
installation of addition'11 extraction welle to
facilitate or accelerate cleanup of the contaminant
plum<>1 and
at individual wells where cleanup goals have been
attainmd, an~ aftar analytical confirmation, pumping
may be diecontinued,
• To e,neure that c1eam1p goals continu" to be maintained, the aquifar
will be rnonitOred at those wells where pumping hae: oeas"d on an
o~currance of every year·following diecontinuation of groundwater.
extraction. This monitoring will be incoi:porated into the overall
aJ.te monitoring prog•·am which will include, the
If, in EPA'a judgment, Lnplementation of the aelected remedy cl~arly
demonstrates, in corroboration with strong hydrogeological and
chemical evidence, that it will be. technico.lly imps·actico.ble to
achieve and maintain remediation goala throughout the o.rc,o. of
attainmentt a groundwater remedy contingency will be developed n.nd
implemented. "I!'or example, a contingency me.y be invoked when it haa
b~en demonSt.rated that oontaffiina1'lt levels have ceased to decline ovftr
time, and are remaining const'ant ,at eome statiet.ioa.lly significant
level above rsmedia.tion goals, in a discrate portion of .the area of
attainmant, aa ·ved.fied by multij'.>le monitoring W<>ll•.
Where euch a contingency situation aris&e, groundwater extraction and
treatment would typically continue ae necessary to achieve ma~e
reduction and remediation goals throughout tha reet of the a1:ea of
attainment.
rt it is determined, on the. baeie or the preceding ci:iteria and th,.
system pertormance data, that.certain portions of the aquifei: cannot
be restored to their beneficial uae, all of the following rneaauree
involving long-term management n1a.y occur,' far ari indefinite pariod of
time, as a modifiaa.tiori of the exii,tiog "Y8tem1
a) engineering controls such ca phyaical barriere, or
long-term gradient control provided.by low level
pumping,· ae: containment me-a.8uro,:,1
b) chemical-specific ARARa will be waived for th<> cleanup
of thoae portion• of the aquifar baaed on the technical
imI',:-actioability of achieving f1.1rther contaminant
reduotion1
c) institutional control a will be p•·ovidc,d/mo.intained to
restrict access to thoae portions of the aquifer which
remain above hsalth-baaGd goala, · aince thil!IJ aqui.f8r ie
claeeified a potential drinking water source/
d) continued monitoring of specified well&/ and
e) periodic reevaluation of rem&dial technologies for
9roundwate1..~ 1.~eator"ation.
Tha d1:toision to _invoke any or all of the~e-metu~uree may be me.de
dui,ing a periodic review of the remedial action, which will occui:-at
every five years.
Statutory Dntarminations
• • The us l';PA. ~ae.s determined that .both t:ha selected ~nd contingency
remedies will eatiefy the follow,tng statutory requiramente of Section
121 ot. CERCLA1 protection of. human health and the an.v~i:onment,
attainir:ig ARARs, coe:t-til_~fectivanaaa, and utiliza.tiofl. of pe1.~manant
aolutione and alternative treatment technologiea to the ma~imum
extent practicabls
Remedial actions per!ormad under C~RCLA must comply with all
applicable or relevant ,and appropriate requir"m"nta (AR/\Re). All
alternativaa considered for the Jadco .... nu,9hee site we.r:'e evaluated on
the basis o! the degree to which the remedy wouhl comply with these
req:uiremente,. The e,el0ct0d remedy was found to meet 01.· exceed the
following AAARa, as preaanted below;.
Cl.,an Water Act/Safe Drinking Water Act,
EPA' a deteminat ion of, appropriate 9roundwater cleanup er i ta1• ia
involved an eva.luat"ion of oonto.mlnant concentrations relative to
available health-b!leed standards. Such limita, including l-laximum
Concentrations Limito (MCLB) and Maximum Concsntration Limit
Goals (I-ICLGa)1 and Fedsral Ambient Water Quality criteria (AWQC),
.section 304 of the Clean water Act {CW/\) used as praacribed in
section l21(d) (2) (b) (i) of CERCLA, "" defined by the safe
Drinking water Act (SDWA) (40 CFR Part 141 and 142) and the clean
Water Act, reepeotivaly, will be achieved by the eelected remedy
praaented in thie decision document.
Toxic Subetancea control Act (TSCA)I
The majority of the PCB contamination detected at the
Jadco-Hugnea aite will be addressed under the interim removal
action. Thie removal action will be conducted in accordance to
thoee requirements.define by TSCA in the disposal of PCBe.
Federal Occupational Safety and Health Administration Act (OSHA):
The. lead party co.nducted and J.mpl8menting the Ren,edial Action
will develop and implement a health and aafety program foi: all
elte workers, All 'oneita workare will meat the minimum training
and ·medical monitorin\l raquiremanta outl.ined in 40 CFR 1910.
Effluent Guidalinea and Standarda, 40 CFR 400 Subchapter N1
FWPC/11
Any discharge to publicly owned treatm&n~ works muat comply with
theee raquiramnts1 the eelected remedy is designed to diacharga
to Belmont POTW1
National Pollution .Discharge Ellimination system,
The substantive requirements ot NPDES must be mat in the event
tha.t the contin9'ency ramady muat be utilized. The oontingency
would b8 to dischar9e to surface w~tera aitha~ on eite or
adjacent to the Jadco~Hughea aita.
North Carolina Superfund Aot1
The State of North Carolina has bean involved with the review and
oversight of the Remedial !nvastigation and Feasibility Study
conducted at the Jadco-Hu11h0s site for the development of this
final remedy daoieion.
• •
North Carolina Groundwatar Regulations/North Carolina Water
Quality standa~d Augu•t 4, 1989;
Many of the final cleanup goals eatabliahed for the Jadoo-Hughe•
eite were dir~ctly from those promulgated groundwater 8tandardu
of North Carolina.
Protection of al)Jllan Health nnd the Environment
The selected and conting~ncy remedies adequately protect human health
by reducing the r: lek of consumption or conta.rni~_ated g~·oundwa.t&r.
This wJ.ll be accompliahed through the captuL·e of the groundwat"r
contaminant plume. Environmental risk will b0 raduoed by elimin~ting
the impact of 9rouhdwatar into the tributary by the replacement of
the culvert aa wall ae -the redirection of the ap.1:ing water.
Treatment of eoila wJ.11 reduoa the eource of contamination to the
9roundwater. No unacceptable ehort-term risks will result from the
i.rnplemant:.ation Of theee rernediea.
Attainment of APPlic@la or Relevant and ApprOPh!ate Reguiromantc
These remedies aasura that the groun.dw11ter at the Jactco-Hughaa site
will meet available MCLa under the sate Drinking Water Act (SDWA) ae
well ae the North Carolina Administrative code, Title 15, Subchapt<,r
2L/ Claeeification and ,water Qual.ity Standards Applicable to the
Groundwaters of North Carolina. ~or those charnicals which do no have
a~si9ned MCLu 04 other ep~cified cl~~nup goal, ·to-be-coneidered
health-baaed values will be attained. Discharge from the groundwater
treatrnant system will mset wither the POTW'a pretreatment st.andards
or NPDES permit dir,charge limits under the Clsan Water Act (CWA).
The CWA ie an applicable requirement, while the SDWA (MCLs) is
relevant and appropriate,
Cost-Bffactivenaae
Alternative 9, tho oelected alt~rnative, iB the most coet-eftactive
remedy that will achieve clean-up goals; T,h" total present worth
coat ie $4,830,900. Alternative 5 1 the contingency alternative,
would p1:ovide a oompa1.·C1.ble level of protection hae a preeent worth
cost of $6,279,900.
The US EPA has determined that the costs of the selected and
contingency alternativee are proportionate to the ov8rall
effaotiveneaa ~nd both are a reaeonable value for the money.
Utilization ot Permantttit Solutions lllld Al.ter:nativo Trua.tment (or
Reqource Recovery) T8:Ch.nOloaias· to the Maximum Extent Praotioabla
IMBP)
Both the selected and contingency alternativea utilii:;et peri\\a.nent
solutions and ~rsatmant technolosioe to the maximum extent
practicable. Both provide short-term and long-term affactivanaaa and
would 1.·educe the toxicity, mobility, and volume through ext1.~a.ction
and treatment of the groundwater. Both would require an estimated 30
yeare to achieve 9,·oundwater clean-up 9oale. Both would require an
eetimated 3 yeare to achisve soil clean-up goale. The nelected
• •
remedy_, Al._ter~ative 9, ia tha moat cost-effective remody but not muy
not be implemantable Uthe city of Belmont POTW or other local POTW
ia unable t~ a~cept dischar9e from the Jadco-Hughes ait.0 wl..thl.n a
reasonable period of time after the signature of this ROD.
Alternative 5 c:oets juot under $1.'5 million more and would become the
selected 1~emedy for the sits if the above cont.ingancy ,lt! not m<,t,
Preferenoa f.or Treatment ae a Principal Element
The etatutory prefersnca for treatment will be meit beca.uoe tha·
principal concern from the Jadco-Hughes site is· ingestion of
contaminated g~oundwa~er. Both the selected and contingency r~mfldie2
will reduce this risk to public health through the capture of tha
91.~oundwatei: plume ae weall ae t~e reduct.lon cf the Bource. of
groundw~ter contamination via nail treatment.
Documentation of SiqnifiOant Changes
Two significant chan11e from the proposed plan is incorporated in this
decision document. The propooed plan recommended that the
groundwater treatment in Alternativa 9 would be utilized with three
diecharge. options I to POTW, to iJurf_aca water with NPOES permit, or
natural infiltration onsite. However, ths Faaeibility Study
iden_ti.~iad a separate ~reatment tor groundwater that would bs mars
eUactJ.ve and more ettecient. tor meetim.i aurrace water .discharge
requiramenta or an NPDEB permit, Additional public comment 10 not
_necese~ry because incorporation of thia technology in Alternative 5
ia conaide1:ed a logical outgrowth of 'the information on which the
public already had the opportunity to comment.
The eeconU aignificant charn;3·e ie the c:ulvei.-t iepla.cement option. The
proposed plan rscommended the poeeibility of removing the buried
oulve):t to eilim.inllte groundwater diecha1.A9e with surface water
di vei.-eion. However, tha repla..oement technology ae identif .Led. in t.he
FS hae bean incorporats-_d into the eelactad remedy, Thie is
predominantly due to storm water and flood control probleme that are
notcoet er.rective to implement. confirmation of the elimination of
groundwater di,.charge muet be analytical.