NCD981023260_20070901_Potters Septic Tank Service Pits_FRBCERCLA LTRA_Five-Year Review 2002 - 2007-OCR

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NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Second Superfund Five-Year Review Report
Potter's Septic Tank Service Pits Site
Sandy Creek, Brunswick County, North Carolina
US EPA ID: NCO 981023260
Prepared for
US EPA Region 4
September 2007
• •
SECOND FIVE-YEAR REVIEW REPORT
POTTER'S SEPTIC TANK SERVICE PITS SITE
US EPA ID: NCD 981023260
Prepared for the
US Environmental Protection Agency
Region 4
R epared by the
of North Carolina
nvironment & Natural Resources
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NCDENR
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September 2007
• •
SECOND FIVE-YEAR REVIEW REPORT
POTTER'S SEPTIC TANK SERVICE PITS SITE
US EPA ID: NCD 981023260
Prepared for the
US EPA Region 4
Prepared by the
North Carolina Department of Environment & Natural Resources
Approved by:
Franklin E. Hill, Division Director
Waste Management Division
US EPA Region 4
R. Donald Rigger, Branch Chief
Superfund Remedial and Site Evaluation Bra
US EPA Region 4
Richard Campbell, Sei,t1
Superfund Remedial and
Section B
US EPA Region 4 ·
Beverly Stepter, RPM
Superfund Remedial and Site Evaluation Branch
US EPA Region 4
Jack Butler, Section Head
NC DENR Division of Waste Management
Superfund Section
Nile Testerman, Environmental Engineer
NC DENR Division of Waste Management
Date
Date
Date
Date
Date
• •
Superfund Section
Table of Contents
List of Acronyms ......................................................................................................................................... iii
Executive Summary ................................................................................................................................... v
Five-Year Review Summary Form ............................................................................................................ viii
1.0 Introduction .................................................................................................................................. 1
2.0 Site Chronology ............................................................................................................................ 3
3.0 Background ................................................................................................................................... 3
3.1 Site Description ............................................................................................................. 3
3.2 Site Topography, Geology, and Hydrogeology... ... . ........ 3
3.3 Land and Resource Use .................................................................................................. 4
3.4 History of Contamination ................................................................................................. 4
4.0 Remedial Actions ......................................................................................................................... 5
4.1 Remedy Selection ........................................................................................................... 6
4.1.1 1992 Record of Decision......... . .......................................... 6
4.1.2 2000 Record of Decision Amend me " ........................................ 7
4.2 Remedy Implementation............................... . ................................................. 8
4.3 System Operation/Operation & Maintenance ................................................. 11
5.0 Progress Since Last Five-Year Review.................... . ........................................... 11
6.0 Five-Year Review Process................................... ..... . ..... .' ................................. 12
6.1 Administrative Components..................... . .............................................. 12
6.2 Community Involvement... ......................................................................................... 13
6.3 Document Review .................................................................................................... 13
6.4 ARAR Review.............................. . ..... 13
6.4.1 Original ARARs from t e ................... 14
6.4.2 Current Applicable ........... 14
6.5 Data Review....... . ................................................................................. 14
6.6 Site lnspectio ......................................................................................................... 16
6.7 Interviews ................................................................................................................. 17
7.0 Technical Assess en .............................................................................................................. 18
7.1 Question A: Is remedy ctioning as intended by the decision documents? ............ 18
7.2 Question B: Are expos e assumptions, toxicity data, clean-up levels and remedial
action objectives Os) ed at the time of the remedy still valid? ............................... 19
7.3 Question C: Has a er information come to light that could call into question
the protectiveness he remedy? ................................................................................. 19
7.4 Technical Assessment Summary .................................................................................... 19
8.0 Issues ........................................................................................................................................... 20
9.0 Recommendations & Follow-up Actions ............................................ : .......................................... 21
10.0 Protectiveness Statement. ........................................................................................................... 21
11.0 Next Review ................................................................................................................................. 21
Tables
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Chronology of Site Event
1992 ROD Specified Remediation Goals for Soil and TCLP Regulatory Limits for Soil
1992 ROD Specified Remediation Goals for Groundwater
2000 ROD Amendment Specified Remediation Goals for Groundwater
Groundwater Analytical Results Over All Monitoring Events
Recommendations and Follow-Up Actions
•
Figures
Figure 1 Site Location Map
Figure 2 Groundwater Sampling Location Map
Figure 3 Water Table Contour Map, Shallow Wells
Attachments
Attachment 1:
Attachment 2:
Attachment 3:
Attachment 4:
Attachment 5:
List of Documents Reviewed
Site Inspection Checklist
Community Notice
Complete Interviews
Photographs
•
ii
ARAR
BTEX
CERCLA
CFR
CLP
COG
EISOPQAM
FIT
IC
IRA
LTTD
MCL
MNA
MSL
MW
NCAC
NCDWA
NC 2L
NC DENR
NCP
NC SWQS
NPL
O&M
OU
QA/QC
RAO
RCRA
•
List of Acronyms
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Applicable or Relevant and Appropriate Requirement
Benzene, toluene, ethylbenzene, and xylenes
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
Contract Laboratory Program
Contaminant of Concern
Environmental Investigation Standard Operating Procedure and Quality Assurance
Manual
Field Investigation Team
/9~ \.;\..
lnst1tut1onal Controls ~\J
Interim Remedial Action ~
Low-Temperature Thermal Desorfion'\.
1
Maximum Contaminant Lev V .)
North Carolin
North Carolina Department of Environment and Natural Resources
National Contingency Plan
North Carolina Surface Water Quality Standards
National Priorities List
Operation and Maintenance
Operable Unit
Quality Assurance/Quality Control
Remedial Action Objective
Resource Conservation and Recovery Act
iii
RD
RI
ROD
RPM
SESD
SOP
TCLP
ug/1
US EPA
voe
•
Remedial Design
Remedial Investigation
Record of Decision
Remedial Project Manager
Science and Ecosystem Support Division
Standard Operating Procedure
Toxicity Characteristic Leaching Procedure
Micrograms per liter
United States Environmental Protection Agency
Volatile Organic Compound
iv
• Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
• • Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Executive Summary
The Potter's Septic Tank Service Pits Site (Site) is situated on a 5-acre tract of
land located in a residential community known as Sandy Creek in a rural section of
Brunswick County, North Carolina. Sandy Creek is divided into one or two acre lots,
most with a private domestic drinking water well. This community is located
approximately one mile west of Maco, North Carolina, and is located immediately south
of US Highway 74/76. From 1969 to 1976, the Skipper family owned the property and
operated sludge hauling and oil spill clean-up companies in the Wilmington, North
Carolina area. Septic tank sludge, oil sludge, and other waste materials were deposited
in shallow unlined pits or directly on the land surface at the Site.
The Site consists of one operable unit, enco
groundwater remedies at the Site. Site related cont
groundwater are currently being monitored for natur
review and is the second Five-Year Review for th 1t
review is September 10, 2002, the signing date e F1
The purpose of this Five-Year Review is to ev h
determine if the action remains protective f h
both the soil and
associated with the
ten · o . This is a statutory
he t · • ering action for this
Five-Year Review Report.
r , edy at the Site and to
Ith nd the environment.
The United States · · • :4gency (US EPA) issued a Record
of Decision (ROD) for t
1992 ROD, was desig
the extent practicable,
remediating all areas
remedial action objectiv
, 1992. The remedial action, as stated in the
inated media at the Site by eliminating, to
mi tion of contaminants present and by
at the Site. As stated in the 1992 ROD, the
the clean up of the Site are:
• To excavate an t at soils that pose a threat to human health and
groundwater;
• To restore contaminated groundwater to levels protective of human health
and the environment; and
• To control exposure to and migration of contaminated groundwater.
The major components of the selected remedy for soil, as stated in the 1992
ROD, include: excavation of all soils exceeding the soil clean-up standards; treatment of
contaminated soil using on-site ex-situ thermal desorption process; secondary treatment
of the concentrated organic contaminants; Sampling and analysis of the treatment
residue; proper transportation and storage of RCRA hazardous wastes; on-site disposal
of the non-hazardous treated soil; and, on-site solidification of soils containing levels of
. chromium, lead, and zinc above clean-up standards for off-site disposal.
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Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
The major components of the selected remedy for groundwater, as stated in the
1992 ROD, include: extraction of groundwater across the Site in the surficial aquifer
that is contaminated above Maximum Containment Levels (MCLs) and/or the North
Carolina Groundwater Standard; on-site treatment of extracted groundwater by
chemical treatment and air stripping to remove contaminants; surface water discharge
of the treated groundwater to Chinnis Branch; and, continued analytical monitoring for
contaminants in groundwater.
The 1992 ROD was modified with a ROD Amendment signed on September 27,
2000. This ROD Amendment modified the groundwater remedy set forth in the 1992
ROD. Based on site-specific data and evaluation reports, the US EPA determined that
the groundwater plume of the Site posed a diminishing threat to human health or the
environment and that the contaminants within the groundwater, as well as in the
saturated zone, could. be remediated through natural attenuation. The ROD
Amendment addressed the implementation of monit ral attenuation (MNA) and
institutional controls (!Cs) as the preferred alternativ undwater restoration at the
Site. The 2000 ROD Amendment also made two ch he groundwater
remediation goals for the Site. The first change low diation goals for
benzene and naphthalene. The second change e co minants 1,2,4-
trimethylbenzene and 1,3,5-trimethylbenzene nts of concern (COCs).
Based on a review of site docume
based on interviews with the US EPA e
DENR RPM, the US EPA has deter .
tal analytical data, and
ager (RPM) and the NC
al attenuation is performing as
monitoring in one small area of the Site anticipated for groundwate wa
indicates that benzene c centrat1 ,
stable over the last fiv rs. This
contaminated soil and gro ·
remedial actions in this are
Some soil benzene contami
o monitoring wells have remained relatively
a i he approximate location of the most highly
sent during the Site Remedial Investigation. Soil
most but not all of the benzene contamination.
ay have been left in place in deeper soil in this
area, because the remedial a
intrusion into the excavation.
soil excavation depth was limited by groundwater
Residual soil contamination may be responsible for the slow reduction in
benzene concentrations in the two monitoring wells. Groundwater monitoring both
downgradient of these wells and in paired monitoring wells at different depths has
shown that benzene is either decreasing or not present and that natural attenuation
limits the area of persistent benzene contamination. Residual benzene mass is beirig
transferred from the soil to groundwater over time. That benzene is being naturally
attenuated.
Additional groundwater monitoring of these two wells over the next few years
should demonstrate if the groundwater benzene contamination is beginning to decrease
as benzene mass is lost from the subsurface. If benzene concentrations in the two
wells remain stable over the next few years, the US EPA will evaluate if additional
vi
• • Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
measures are needed to address the benzene mass to accelerate attainment of
groundwater remedial action objectives.
The exposure assumptions, toxicity data, clean-up levels and RAOs used at the
time of the remedy are still valid for the COCs. There are no current exposure routes
to the groundwater and the remedy, in the short-term, is still protective of human health
and the environment. No other information has come to light that would call into
question the short-term protectiveness of the remedy. However, in order for the remedy
to be protective in the long-term, restrictive covenants or other appropriate institutional
controls must be implemented at the Site.
vii ·
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Site name (from WasteLAN): Potter's Septic Tank Service Pits Site
US EPA ID /from WasteLAN): NCO 981023260
Region: 4 City/County: Sandy Creek, Brunswick County
NPL status: 0 Final □ Deleted □ Other (specify)
Remediation status (choose all that apply): □ Under Construction 0 Operating
D Complete
Multiple OUs?• □YES 0 NO
Has site been put into reuse? □ YES 0
Review period: 3 / 26 I
Date(s) of site inspection.
Type of review: Statutory
Review number: 01 (first) 0 2 (second) □ 3 (third) □ Other
Triggering Action:
D Actual RA Onsite Construction at OU # __
D Construction Completion
D Other
□Actual RA Start
[8] Previous Five-Year Review Report
Triggering action date /from WasteLAN): 9 / 10 / 2002
Due date (five years after triggering action date): 9 I 10 / 2007
viii
• • Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Five-Year Review Summary Form, cont'd
1. Institutional controls for the Site as proposed in the documents of record
have not been implemented.
Recommendations and Follow-up Actions:
Major recommendation: 1. Implement restrictive covenants or other appropriate
institutional controls at the Site.
Protectiveness Statement:
As stated in the 1992 Record of Decision (ROD), 20 mendment, and/or
the forthcoming ESD, the goal of the Potter's Pits re ·o is to reduce on-
site levels of contamination as to allow for unli · , • stricted
exposure. It appears that natural attenuation of is performing as
anticipated and that clean-up levels will event lly • . The remedy at
the Site currently protects human health and t because the main
source of contamination was remediated o oval and no human
or ecological exposure pathways exis dwater or soil in the
short term. However, in ord.rill~ r y to be protective in the long-term,
the following action need o be t : I ment restrictive covenants or other
appropriate institution trols at t Sit
ix
•
1.0 Introduction
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
The purpose of conducting a Five-Year Review is to determine whether the
remedy implemented at a Site is protective of human health and the environment. The
methods, findings, and conclusions of this review are documented in the Five-Year
Review Report. In addition, Five-Year Review Reports identify issues found during the
review, if any, and identify recommendations to address them.
The North Carolina Department of Environment and Natural Resources (NC
DENR), Division of Waste Management, Superfund Section, on behalf of the United
States Environmental Protection Agency (US EPA), Region IV, has conducted a Five-
Year Review of the remedial actions implemented at the Potter's Septic Tank Service
Pits Site (Site) (US EPA ID# NCO 981023260). The Site is located in a rural section of
Brunswick County, North Carolina, in a residential c known as Sandy Creek,
North Carolina. The review was conducted from M through September 2007
and the results of the review are documented in this he review was conducted
in accordance with the Comprehensive Environmen , Compensation, and
Liability Act (CERCLA) §121 and the National Co ting (NCP). CERCLA §121
states:
If the President selects a remedial action th
or contaminants remaining at the site, the
often than each five years after the initi 1
ha rdous substances, pollutants,
ev · such remedial action no less
of su edia ction to assure that human
health and the environment ted by the remedial action being implemented. In
ge 1 nt of the President that action is appropriate at
•' Jo 06], the President shall take or require such
addition, if upon such revi
such site in accordance 11
action. The President sh
required, the results of alls
port to t Congress a list of facilities for which such review is
review and any actions taken as a result of such reviews.
The US EPA interpret
Hazardous Substance Pollutio
states:
· requirement further in the National Oil and
ontingency Plan (NCP); 40 CFR §300.430(f)(4)(ii)
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and unrestricted
exposure, the lead agency shall review such action no less often than every five years after
the initiation of the selected remedial action.
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
The methods, findings, conclusions, and significant issues found during the
review are documented in this Five-Year Review report. This Five Year Review was
performed in a manner consistent with the latest US EPA Comprehensive Five-Year
Review Guidance (US EPA, 2001).
The Site consists of one operable unit, encompassing both the soil and
groundwater remedies for the Site. Site-related contaminants associated with the
groundwater are currently being monitored for natural attenuation. It appears that
natural attenuation of groundwater and soil is performing as anticipated and that clean-
up levels will eventually be attained. As a result, this is a statutory review. The
triggering action for this review is September 10, 2002, the signing date of the First
Five-Year Review Report. A statutory review is conducted when "upon completion of the
remedial action, hazardous substances, pollutants, or contaminants will remain on Site
above levels that allow for unlimited use and unrestri x osure" (US EPA
Comprehensive Five-Year Review Guidance, June ction 1.3.1 ). In accordance
with CERCLA §121 and the NCP, a statutory review ed by the initiation of the
first remedial action that leaves hazardous substanc , or contaminants on
site above levels that allow for unlimited use and n e osure. As stated in
the 1992 ROD and/or 2000 ROD Amendment, oal he remedial action is to
reduce on-site levels of contamination as to al ed use and unrestricted
exposure.
The purpose of this Five-Year i remedy at the Site and
to determine if the action re ote of human health and the environment.
More specifically, the pu[
• To confirm t
Amendment, aIns
environment (i. •
and
dy, as specified in the 1992 ROD and 2000 ROD
ective at protecting human health and the
emedy is operating and functioning as designed),
• To evaluate wh er the cleanup levels specified in the ROD/ROD
Amendment remain protective of human health and the environment.
2
•
2.0. Site Chronology
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Table 1 lists the Site chronology for selected events for the Site.
3.0 Background
3.1 Site Description
The Site is situated on a 5-acre tract of land located in a residential community
known as Sandy Creek in a rural section of Brunswick County, North Carolina. Sandy
Creek is divided into one or two acre lots, most with a private domestic drinking water
well. This community is located approximately one mile west of Maco, North Carolina,
and is located immediately south of US Highway 7 4/7 T~he S .. ite is comprised of three
lots and no homes or domestic wells are located on se ee parcels of property.
Figure 1 shows the Site location and topographic m of area.
3.2 Site Topography, Geology, and H eol
The Site is located in the eastern part o tlan · • Coastal Plain physiographic
region. Shallow water tables and low topogra hie ·e c acterize this part of the
coastal plain. Near-surface stratigraphy c si of riet of predominantly elastic
sediments but includes shell and peat e s. the a are classified as
Baymeade fine sand and For I fine sa types that overlay a limestone or
calcareous sandstone for ittent clay layer at a level of 30 to 40 feet
divides the shallow gro r the deeper aquifer in the area. The Site
extends from an uplana ying wetland bordering Chinnis Branch on the
east. Drainage from the s st toward Chinnis Branch, which eventually flows
into Rattlesnake Branch; ho e Site is located on a groundwater divide.
The groundwater unde e Site is designated as Class GA in accordance with
the North Carolina's Ground ater Classification System and Class IIB under the US
EPA Groundwater Classification Guidelines. The Class GA classification means that
the groundwater is an existing or potential source of drinking water supply for humans
as defined in Title 15A, North Carolina Administrative Code, Subchapter 2L (T15A
NCAC 2L). The US EPA classifies the upper zone of the aquifer (i.e., the groundwater
above the blue clay layer) as Class IIB since the aquifer is of drinking water quality but
is not currently being used as a source of drinking water. The groundwater beneath the
blue clay layer is assumed to be interconnected with the Castle Hayne Limestone
formation and is therefore, classified as IIA. Class IIA is defined as an aquifer that is
currently being used as a drinking water source. The Castle Hayne is a major drinking
water source for Brunswick County, North Carolina.
3
I.
•
3.3 Land and Resource Use
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
· The current and anticipated future land use for the surrounding area is
residential. Residential lots within the area are generally one to two acres in size with
most lots having domestic water well; however, no homes or domestic wells are located
on the parcels of property that make up the Site. The land immediately northeast, north,
west, and south of the Site is forested land. This wooded area extends approximately
300 to 500 feet west and 800 feet south of the Site.
3.4 History of Contamination
From 1969 to 1976, the Skipper family owned the property and operated sludge
hauling and oil spill clean-up companies in the Wilmilill'i'i:lih~ orth Carolina area. Septic
tank sludge, oil sludge, and other waste materials w sited in shallow unlined pits
or directly on the land surface at the Site. There are s to discern the exact
materials disposed within the pits or on the land surf
In May 1976, the North Carolina Depart , of
informed Mr. Ward Skipper that an oil disposa pit
Carolina statues and must be cleaned up · diat
ral Economic Resources
was in violation of North
at time, approximately
nd the pit area was 2,000 to 3,000 gallons of black oil was
covered with soil. Documentation pe ng to chemical composition of material
disposed in the pit, the fate id
characteristics of the m ial buri
oved from the pit, and the quantities and
have never been found.
In August 1976, th earthen berm allowed approximately 20,000
gallons of oil to escape fro n unli d pit at the Site. The oil flowed into an on-site·
creek, Chinnis Branch, whic l e igrated to Rattlesnake Creek. The U.S. Coast
Guard responded pursuant to ction 311 of the Clean Water Act and used
containment booms to provid an initial remedial clean up of the surface waters. The oil
in adjoining wetland areas could not be removed. After the spill in August 1976, Mr.
Otto Skipper (Ward Skipper's brother), pumped the remaining 20,000 gallons of oil from
the remaining pits into tank trucks and hauled the waste off site. The bottom sludges
and some oil stained soils were excavated and disposed of in the Brunswick County
Landfill. The remaining thicker sludges, which could not be pumped, were mixed with
sand and buried on site; however, the burial location was not documented.
Between 1980 and 1983, the property surrounding the Site changed ownership
and was developed and subdivided into one and two acre residential lots. This
development became known as Sandy Creek Acres, and later as Sandy Creek, North
Carolina. In July 1983, one property owner discovered creosote, oil tank bottoms
sludges, and septic tank sludges in his yard. The State of North Carolina sampled and
4
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
analyzed the soils and groundwater and confirmed the presence of contamination,
resulting in the condemnation of the property owner's drinking water well due to
unacceptable levels of benzene. The property was then temporarily connected to a
neighbor's well system.
In September 1983, the US EPA and the Region 4 Field Investigation Team (FIT)
performed an electromagnetic survey of the Site, monitored the air under the home of
the on-site property owner, and collected soil, surface water, and groundwater samples
for laboratory analysis. In February 1984, the US EPA also used ground-penetrating
radar to further delineate the boundaries of contamination. In March 1984, the US EPA
Office of Emergency Management and Remedial Response requested an Immediate
Removal Action (I RA) to remove the soil source of contamination. Approximately 1,770
tons of contaminated soil were removed from the Site and hauled to a hazardous waste
landfill in South Carolina. Nine groundwater monitor' II were installed and
sampled as part of the removal action. The sample wer nalyzed for volatile organic
compounds (VOCs). Benzene, toluene, ethylebenz . e lenes (BTEX) were
detected in the groundwater samples. The wells wer gain pied in 1988 by the
State of North Carolina and the predominant cont s w BTEX and phenols.
The Site was placed on the National Priorities March 31, 1989. In 1989
and 1990, the Remedial Investigation (RI) wa assess the nature and
distribution of contaminants at the Site. R su re published in an RI
Addendum Report in July 1991. A Feasi y ich develops and analyses
alternatives for remediation at the Sit s iss ublic in April 1992. Based on
the RI/FS, the US EPA sele ed remedial action alternative which, after
public comment, becam nal in t OD.
4.0
The purpose of the re di action, as stated in the 1992 ROD, was to address
contaminated media at the Sit eliminating, to the extent practicable, the volume and
migration of contaminants pr ent and to remediate all areas of contamination at the
Site. As stated in the 1992 ROD, the remedial action objectives (RAOs) for the clean up
of the Site are:
• To excavate and treat soils that pose a threat to human health and
groundwater;
• To restore contaminated groundwater to levels protective of human health
and the environment; and
• To control exposure and to control migration of contaminated
groundwater. ·
Because this remedy resulted in hazardous substances, pollutants, or
contaminants remaining on site above levels that allow unlimited use and unrestricted
5
• •
Five-Year Review
Potters Septic Tank SeNice Pits
Sandy Creek, Brunswick County, NC
exposure (i.e., contaminated soil and groundwater), Five-Year Reviews will be
completed to assess site conditions, contaminant distributions, and any other
associated site hazards. ·
4,1 Remedy Selection
4, 1.1 1992 Record of Decision
The remedy set forth in the 1992 ROD provides for remediation of contaminated
soil and groundwater. The major components of the remedy include:
Soil
• Relocation of the residents before remedial activities begin;
• Excavation of all soils exceeding the soil c -~tandards established in
the ROD;
• Treatment of contaminated soil using on-s -thermal desorption
process;
• Secondary treatment of the concentrate ic c . minants, a by-product
of thermal desorption;
• Sampling and analysis of the treat
• Proper transportation and stora e ous wastes;
• On-site disposal of the non-ha
areas, backfilling with soil t •
• On-site solidifica ·
above clean-u tandar
Groundwater
into the original excavated
egat ing with native grasses; and,
taining levels of chromium, lead, and zinc
site disposal.
• Extraction of gro , water cross the Site in the surficial aquifer that is
contaminated abo mum Containment Levels (MCLs) and/or the North
Carolina Groundwa tandard;
• On-site treatment o extracted groundwater by chemical treatment and air
stripping to remove contaminants;
• Surface water discharge of the treated groundwater to Chinnis Branch; and,
• Continued analytical monitoring for contaminants in groundwater.
Tables 2 and 3 show the remediation goals for soil and groundwater under the
1992 ROD.
6
• •
Five• Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
4.1.2 2000 Record of Decision Amendment
The 1992 ROD was modified by the 2000 ROD Amendment. The 2000 ROD
Amendment modified the groundwater restoration approach of the 1992 ROD. The US
EPA determined that all soil remediation had been completed based upon the clean-up
goals established within the 1992 ROD and Remedial Design (RD). Site-specific data
indicated that the groundwater plume of the Site posed a diminishing threat to human
health or the environment. Based on results of additional sampling, a June 2000
Evaluation Report, and a September 2000 Supplemental Evaluation Report, the US
EPA determined that the contaminants within the groundwater, as well as in the
saturated zone, could be remediated through natural attenuation. A Final Feasibility
Study Addendum Report was issued on September 27, 2000. The resulting 2000 ROD
Amendment addressed the implementation of monit t ral attenuation (MNA) and
institutional controls (!Cs) as the preferred alternativ undwater restoration at the
Site. The major components of the MNA and IC alt I elude:
• Groundwater monitoring program to
migration;
• Periodic sampling and analysis
contaminants have degrade
• Installation of seven deep a
monitoring efforts; and,
oncentrations and
r to determine if
e monitoring wells to aid in
• lmplementati
specific ar
ed recordation and restrictions of use of
erlying impacted groundwater.
The 2000 ROD A dment a o made two changes to the groundwater
remediation goals for the S First he remediation goals for benzene (5 ug/I) and
naphthalene (30 ug/I) were g to 1 ug/I and 21 ug/I, respectively. The current
remediation goals for benzen ug/I) and naphthalene (21 ug/I) are the State of North
Carolina's Groundwater 2L S ndards. Second, the contaminants 1,2,4-
trimethylbenzene and 1,3,5-trimethylbenzene are now included as COCs. The
remediation goal for both of these contaminants is 60 ug/1. The metals of concern
(chromium and lead), in the original ROD were retained, although evidence showed that
the groundwater concentrations of these metals have decreased over time to levels
below the ROD groundwater remediation goals or were not actually present as
significant concentrations of mobile phase contamination when they were detected.
Table 4 is the Revised Groundwater Remediation Goals as stated in the 2000
ROD Amendment.
7
•
4.2 Remedy Implementation
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
I .
In 1993, the RD efforts to implement the source and groundwater remediation
requirements of the 1992 ROD were initiated. As required by the ROD, the source
remediation design included excavation of soils having contaminant concentrations
above the clean up levels, treatment of soils by low-temperature thermal desorption
(L TTD), stabilization of high concentrations inorganic soils, and placement of the treated
soil on site in accordance with regulation and engineering guidelines. The design also
included the implementation of a groundwater recovery and treatment system to
remediate the groundwater contamination.
In June 1995, the US EPA began on-site treat
the ROD, contaminated soil was treated on site by L move the volatile
contaminants. Following the L TTD treatment, each tion was sampled and ·
analyzed to determine whether concentrations of et • city Characteristic
Leaching Procedure (TCLP) regulatory limits. ime, it was determined, by
the US EPA, that subsurface excavation plan 'ner of Joe Baldwin and
Hickory Drives was technologically infeasi le esidual area planned for
excavation below the ground surface at t el n sea level (MSL) due to
water intrusion. The US EPA made t mod ens a er on-site field activities had
begun. Table 2 is a list of th~:liill.! lean-up goals, and the TCLP regulatory limits.
By April 1996, all on-site ii with nt concentration levels above the clean-up
goals, with the excepti SL (saturated zone), were excavated and
treated.
Approximately 32,000 ic rds of soil were excavated. Treated soil that met
the ROD-specified dean up g was used for excavation backfill. Treated soil that
had carcinogenic polycyclic a matic hydrocarbons (PAHs) concentrations above
detection levels and zinc above 122 mg/kg, required placement below the top one foot
of backfill. All excavated material met the clean up standards for lead and zinc and,
therefore, solidification and stabilization were not needed to meet the ROD
requirements. In June 1996, backfilling of the treated material was completed.
Approximately 4,000 cubic yards of clean soil was imported for the final grading and to
provide the one-foot cover for the treated material containing carcinogenic PAHs
concentrations above the detection levels. Following the placement of the final soil
cover, the Site was seeded and mulched.
8
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
From 1996 to 1997, two hurricanes and one tropical storm produced heavy rainfall
events that caused severe erosion at the Site. In late 1997, the State of North Carolina
submitted a notice of violation for site erosion. In October 1997, the US EPA
subcontractor conducted site restoration at the US EPA's request. In December 1997,
the State of North Carolina requested additional site restoration. The US EPA's
subcontractor completed the final restoration in February 1998.
In an effort to address Site erosion issues, the US EPA included erosion
prevention/control use restrictions in the institutional control portion of the remedy set
forth in the 2000 ROD Amendment. As documented in a letter from NC DENR, erosion
no longer appears to be a problem at the Site. The US EPA1agrees with NC DENR's
conclusion and, as a result, has decided to remove the erosion prevention/control
institutional control requirement from the remedy. T · ision will be documented. in
an ESD or a note to file for the Site.
As stated in the Close-Out Report for the Sou • Re i lion for the Potter's
Pits Site, the ROD source remedy is operational f lion s confirmed through
sampling and analysis results that indicate the als were met for the treated
materials. Based upon the provisions of the 1 92 D, edial design, US EPA
Region IV, Standard Operating Procedure ( Ps), th subcontract provisions, it
was determined that the performance sta for s ce remediation project were
met, except for two areas as directed Th exceptions were in the areas
of subsurface contaminatio_.,.~ of Joe Baldwin and Hickory Drive and the
material below elevation MSL. eas were unable to be excavated due to
groundwater intrusion.
Residual soil conta , lion y be responsible for the slow reduction in
benzene concentrations int onitoring wells. Groundwater monitoring both
downgradient of these wells a paired monitoring wells at different depths has
shown that benzene is either ecreasing or not present and that natural attenuation
limits the area of persistent benzene contamination. Residual benzene mass is being
transferred from the soil to ground water over time. That benzene is being naturally
attenuated.
Additional groundwater monitoring of these two wells over the next few years
should demonstrate if the groundwater benzene contamination is beginning to decrease
as benzene mass is lost from the subsurface. If benzene concentrations in the two
wells remain stable over the next few years, the US EPA will evaluate if additional
measures are needed to address the benzene mass to accelerate attainment of
groundwater remedial action objectives.
9
•
Groundwater
•
Five-Year Review
Potter's Septic Tank SeNice Pits
Sandy Creek, Brunswick County, NC
The 1992 ROD for groundwater at the Site specified a groundwater remedial
action that included extraction of contaminated water, chemical treatment and air
stripping, and treated water discharge into a nearby stream. In June 2000, the US EPA,
Science and Ecosystems Support Division (SESD) provided additional data for the
evaluation of MNA as a remedy for groundwater contamination. Based on the large
volume of source material removed and treated during the soil remedial action, the
groundwater remedial action was re-evaluated. The groundwater investigation
consisted of the installation and sampling of seven new monitoring wells in addition to
the collection of groundwater samples from ten existing monitoring wells and five
potable residential wells. The investigation indicated that groundwater contamination
remained at the Site above remediation goals establi Y. the 1992 ROD. In
addition, two trimethylbenzene compounds (1,2,4-tri. eth I enzene and 1,3,5-
trimethylbenzene) were found in significant concent · ich prompted the US EPA
to conduct additional risk calculations on these comP, • ed on these new
calculations, a total trimethylebnzene concentrati f mg as established as a
risk-based groundwater clean-up goal in additi • the an-up goals presented in the
1992 ROD (Koporec, US EPA, Risk Assessm t c ulat • s for Trimethylbenzenes,
August 2000). The results of the SESD gr u • wat es ation were used to
evaluate groundwater natural attenuation oc se th ite using a groundwater
modeling program (BIOSCREEN) th pplic to the atural attenuation of
dissolved hydrocarbons. B his estigation, subsequent data, the June 2000
Evaluation of Monitored a • at the Potter's Pits Site, Sandy Creek,
North Carolina (Olstei , 20 ) Report, and the September 2000
Supplemental Evaluation S EPA determined that natural attenuation was a
viable groundwater remedi . It was also concluded, based on the June
2000 Evaluation of Monitore ttenuation report, that when low flow sampling
was utilized during sampling , chromium and lead were below detection limits;
therefore, these contaminant no longer analyzed for during the quarterly
· sampling events.
As stated in Section 4.2 of this report, the 1992 ROD was amended in September
2000 to include the new groundwater remedial action of MNA and I Cs. The US EPA
also made two changes within the 2000 ROD Amendment regarding groundwater
remediation goals. The clean-up goals for benzene and naphthalene were revised to
reflect the changes in the North Carolina Groundwater 2L Standards. These new
remediation goals were reported as 1 ug/L for benzene and 21 ug/L for naphthatlene.
In addition, two new trimethylbenzne compounds were added to the COCs for the Site
based on the June 2000 groundwater investigation.
10
• •
Five-Year Review
Potter's Septic Tank SeNice Pits
Sandy Creek, Brunswick County, NC
As stated in the September 2003 Draft Remedial Action Report, a total of twelve
additional monitoring wells (five shallow and seven deeper wells) were installed for the
MNA groundwater remedial action. A groundwater monitoring program was initiated
and the remedial action began in 2002. As part of the Groundwater Monitoring Program
initiated in 2002, quarterly groundwater monitoring was recommended.
4.3 System Operation/Operation and Maintenance
The US EPA's contractor, Black & Veatch, completes all operation and
maintenance (O&M) activities at the Site. The wells were sampled and inspected during
the March 2002, June 2002, November 2002, March 2003, November 2006, February
2007 and May 2007, groundwater monitoring events. All groundwater samples are
analyzed for Contract Laboratory Program (CLP) VO a d CLP extractable organic
compounds. Additionally, samples are analyzed for kali · , and total and ferrous iron.
Complete rounds of water level measurements are II t -during each sampling
event to construct potentiometric surface maps of th
As stated in the Evaluation of Monitore
Site, June 2000 Report, the 1992 ROD signifi ntl vere ·mated the scope and cost of
the groundwater extraction remedy, with e ·mat • ost f $7,000,000. Based on
the new MNA groundwater remedy, the i sti d e $800,000. The 2000
ROD Amendment states that it is exp that groun water contaminant levels will
be reduced by natural attenu:a>t!Qt d I continue to be below the established
remediation goal for ben e, eth nz , and naphthalene in less than 4 years. The
natural attenuation for , -trimethl . · enz . e should reach remediation goals in
groundwater in approxim 5 year for areas north of Joe Baldwin Drive· and less
than 15 years for the area th of e Baldwin Drive.
5.0 ive-Year Review
This is the Second Five-Year Review Report. During the First Five-Year Review,
no deficiencies were discovered. The Protectiveness Statement expressed the
protectiveness of the remedial actions and that the site was protective of human health
and the environment. The protectiveness statement, as written in the 200_2 Five-Year
Review, stated:
"The remedy at the Potter's Septic Tank Service Pits Site currently protects
human health and the environment because the main source of contamination
has been remediated through the L TTO treatment of the contaminated soils.
However, in order for the groundwater remedy to be effective in the long-tenn,
the following actions need to be taken to ensure long-term protectiveness:
Implementation of the Institutional Controls delineated in the AROD."
11
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
The two recommendations made during the Five-Year Review Report dated
September 10, 2002 were:
• Institutional controls for the Site as proposed in the documents of record
have not been implemented.
• Monitoring wells need to be checked to ensure all are properly secured to
prevent tampering. ·
Since the last five-year review, the US EPA has had several discussions with the
property owners of the Site regarding the implementation of institutional controls;
specifically, the recording of restrictive covenants and a deed notice. Implementation of
institutional controls on one of the parcels has been delayed due to the
uncooperativeness of the property owner. The US E e aluating its options with
respect to this property owner. Discussions concer mplementation of
institutional controls on the other parcels made som s before becoming
sidetracked. The US EPA has recently resumed dis these property
owners and is hopeful that institutional controls wi I e ed for these parcels in
the near future.
Since the last five-year review, the G ou on ring Program was initiated
in March 2002 with quarterly groundwate ing n commended. On
September 30, 2003, Black & Veatch ared , subm ed the Final Remedial Action
Report summarizing the an of the first four consecutive sampling events
(March 2002, June 2002 oveml:i and March 2003). The report concluded that
the groundwater conta · nts, with few ceptions, appeared to be diminishing with
time (see Section 6.5 Oat eview o his report for further discussion of this matter).
From March 2003 to Nove • r 200 , the recommended quarterly groundwater
monitoring was not conduct . T US EPA recognizes there was a gap in sampling .
data between March 2003 an vember 2006 which was the result of contracting
issues. The contracting issue hat lead to the data gap have since been resolved and
quarterly sampling is back on schedule with MNA Quarterly Groundwater Sampling
Data Summary reports having been submitted to the US EPA in January 2007 and May
2007. These three most recent sampling events seem to indicate that groundwater
contaminants are continuing to decrease with time.
6.0 Five-Year Review Process
6.1 Administrative Components
The NC DENR, Superfund Section, performed the five-year review process for
the Potter's Pits Site. Nile Testerman (Environmental Engineer) and Stephanie Grubbs
(Hydrogeologist) from NC DENR were responsible for gathering and reviewing data for
12
• •
Five-Year Review
Potters Septic Tank SeNice Pits
Sandy Creek, Brunswick County, NC
this review and compiling all the information into the Five-Year Review Report for the
US EPA. Telephone and/or email discussions/interviews with Beverly Stepter, US EPA
Remedial Project Manager were conducted. Other activities conducted for this review
include document review (see Attachment 1 ), completion of a Site Inspection Checklist
(see Attachment 2), a public notice submitted to the local newspaper (Attachment 3),
community interview documentation (see Attachment 4), and the Five-Year Review
Report preparation.
6.2 . Community Involvement
All community involvement activities regarding the remedial activities for the Site
were conducted by the US EPA. The community was notified via a public notice in the
local newspaper, The Star News, regarding the five-Y. view process at the Site. A
public notice was placed in The Star News on Febr ry 2 007. A copy of the public
notice is included in Attachment 3. Several commu iews were also conducted.
See Section 6.7 of this report for a summary of the i ducted and
Attachment 4 for a complete list of the comments/is y the community.
After the five-year review has been app
placed in The Star News informing the comm
report will be available at the US EPA Re• d
Atlanta, GA 30303; the Leland Library Viii
on the US EPA website (hit ·
6.3
PA, a notice will be
plete Five-Year Review
r, 61 Forsyth Street, SW,
nd, North Carolina; and,
.htm .
This Five-Year Rev1 d of a review of relevant documents including the
signed ROD, ROD Amend t, C e-Out Report for the Source Remediation Report,
Remedial Action Report, MN rterly Sampling Data Summary Reports, and the
previous Five-Year Review R ort. Applicable soil and groundwater clean-up
standards and other ARARs, as listed in the ROD and ROD Amendment, were also
reviewed and checked for updates. See Attachment 1 for a complete list of documents
reviewed.
6.4 · ARAR Review
In performing the Five-Year Review for compliance with applicable or relevant
and appropriate requirements (ARARs), only those ARARs addressing risk posed to
human health and the environment (i.e., addressing the protectiveness of the remedy)
were reviewed. This is in keeping with current US EPA guidance on five-year reviews.
13
•
6.4.1 Original ARARs from the 1992 ROD
Federal ARARs
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
• Federal Groundwater Classification (55 Federal Register Part 8733)
• Safe Drinking Water Act (40 USC Section 300, 40 CFR Part 141)
• Clean Water Act, Dredge and Fill Requirements (40 CFR 230)
• Solid Waste Disposal Act (40USC 6901 -6987, 40 CFR Part 261)
• US EPA Regulations on Sole-Source Aquifers (40 CFR 149)
State ARARs
• North Carolina Solid Waste Disposal Regulations (North Carolina
Administrative Code (NCAC), Title 15 Chapter 13B)
• Regulations for the Management of s Waste promulgated
under the authority of the NC Waste ent Act (NCAC Title 15A,
Chapter 13A)
• NC Drinking Water and Groundwate
Classifications and Standards (N C T1
• NC Surface Water Quality Sta (N QS) Classification and
Water Quality Standards (NC j A · apter 2B)
• NC Drinking Water Act (N ,. ral tatutes Chapter 130A,
NCAC 311-327)
6.4.2
For the current gro edy, site-specific ARARs are identified as
follows: Maximum contami t level (MCLs) and groundwater standards specified in
NCAC 2L are ARARs for sit ou water. Both the original remedy and the amended
remedy are designed to obtai ARs throughout the entire Site. The ARARs for the
soil remedy were met for all s excavated and treated as part of the remedial action,
with the exception of two areas (subsurface contamination at the corner of Joe Baldwin
and Hickory Drive and the material below elevation 38 MSL).
6.5 Data Review
Activities conducted at the Site were consistent with the 1992 ROD and the 2000
ROD Amendment and all the work plans prepared for the design and implementation of
the RA, including sampling and analysis. All the US EPA and NC DENR quality
assurance and quality control (QA/QC) procedures and protocol were incorporated into
sampling and analysis plans. The US EPA analytical methods were used for all
validation and monitoring samples during and post RA activities. Sampling of soil and
water followed the US EPA protocol, Environmental Investigations Standard Operating
14
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Croek, Brunswick County, NC
Procedures and Quality Assurance Manual, May 1996 (EISOPQAM), US EPA, Region
4, Science and Ecosystem Support Division, as revised, and Test Methods for
Evaluating Solid Wastes, Physical/Chemical Methods.
Soil
As stated previously in Section 4.2, Remedy Implementation, the performance
standards· for the _soil remediation have been met with the exception of two areas:
subsurface contamination at the corner of Joe Baldwin and Hickory Drive and the
material below elevation 38 MSL. It was technologically infeasible to remove the
residual area planned for excavation below the ground surface at the elevation 38 mean
sea level (MSL) due to water intrusion. The US EPA made these modifications after on-
site field activities had begun.
Groundwater
The Groundwater Monitoring Program was in
of four consecutive groundwater sampling events (
2002, and March 2003). The most current groundw
completed in November 2006 and January/Febru
Supplemental Evaluation of Monitored Natural
Sandy Creek, North Carolina (2000), all grou wa
been analyzed for: dissolved oxygen (DO al lini
temperature, BTEX, naphthalene, and 1, 1,
2002 with the completion
2, June 2002, November
·n events were
ecommended in the
the Potter's Pits Site,
s collected to date have
d ferrous iron, pH,
thylbenzene.
Based on the M NA
Summary Report by Bia
r , dwater Sampling (2007, 1st Quarter), Data
c · din May 2007, the following conclusion was
made:
"Groundwater con/a ants, ith few exceptions, appear to be diminishing with
time. Along the north ion of the site, naphthalene contamination has
decreased significant/ onitoring wells PP-MW-106, PP-MW-302, and PP-
MW-305. In the centr portion of the site, monitoring wells PP-MW-401 has
shown a significant decrease in concentrations of toluene, xylenes, and 1,2,4-
trimethylbenzene. However, this monitoring well has exhibited relatively stable
concentrations of benzene. In other monitoring wells where contamination has
been observed (PP-MW-110, PP-MW-301, PP-MW-403, PP-MW-404, PP-MW-
405, and PP-MW-406), concentrations have remained relatively stable, or have
shown mixed results over time. Monitoring well PP-MW-407 is the only well to
show a significant increase in contaminants over the monitoring program. In this
well, stable levels of site related constituents were detected in the first three
sampling periods; however, a dramatic increase was noted in the March 2003
sampling period, and though most contaminants diminished in the 2006 sampling
period, the. contaminant 1, 3, 5-trimethylbenzene indicated an increase from the
2003 sampling period. However, the sample collected in January 2007 exhibits a
15
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
significant decrease in the previously elevated concentrations of benzene,
toluene, xylenes, ethylbenzene, and the trimethylbenzenes."
Since the last Five-Year Review Report in 2002, six sampling events have been
completed. Based on the most recent data, benzene, naphthalene, and 1,2,4-and
1,3,5-trimethylbenzene are the only contaminants that have exceeded remediation
goals within the past 5 years. Benzene, however, was the only COC detected above its
remediation goal during the last sampling event in February 2007. The five monitoring
wells with benzene exceeding the remediation goal of 1 ug/L are:
• PP-MW-401 (benzene, 46 ug/L)
• PP-MW-403 (benzene, 13 ug/L)
• PP-MW-404 (benzene, 17 ug/L)
• PP-MW-406 (benzene, 1.9 ug/L)
• PP-MW-407 (benzene, 5.5 ug/L).
Residual soil contamination may be responsi
benzene concentrations in the two monitoring wells.
downgradient of these wells and in paired monitor'n
shown that benzene is either decreasing or not ent
limits the area of persistent benzene contami tic Res1
transferred from the soil to ground water o t b
attenuated.
slow reduction in
r monitoring both
erent depths has
that natural attenuation
al benzene mass is being
zene is being naturally
Additional groun
should demonstrate if
of these two wells over the next few years
ene contamination is beginning to decrease
as benzene mass is lo
wells remain stable ov
measures are needed to
groundwater remedial ac
urf . If benzene concentrations in the two
ears, the US EPA will evaluate if additional
benzene mass to accelerate attainment of
Table 5 is the historica ummary of the groundwater analytical results since
2002. Figure 2 shows the groundwater sampling locations at the Site. Figure 3 is the
water table contour map for the shallow wells at the Site.
6.6 Site Inspection
The Site inspection of the Potter's Pits Site was conducted on May 15, 2007.
Attending the Site visit was:
• Nile Testerman, Environmental Engineer, NC DENR, Superfund Section
During the inspection, all groundwater monitoring records were noted as readily
available in office and up-to-date. All monitoring wells were secure, functioning, locked,
16
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
and in good condition. The US EPA's subcontractor, Black & Veatch, conducts O&M at
the Site. All O&M records are up-to-date and available in office. See Attachment 2 for
the completed site inspection checklist.
6.7 Interviews
The following person was interviewed regarding the activities and implementation
of the remedial actions at the Potter's Pits Site. Only portions of the
interviews/community interviews are stated below. For the complete interview
statement see Attachment 4.
Beverly Stepter, US EPA RPM:
Overall impression of the project: "The five-year review is to assess the
protectiveness of the remedy at the Potter's Pits he remedy outlined in the
ROD is Monitored Natural Attenuation and Instil ontrols. The ROD identifies
an adequate level of protection for the site. In m
protective of human health and the environment.
come to light that could question the protective
has been substantially completed. Ground
the remedy remains
other information that
the edy. The soil cleanup
inants at the site appear to
still be required and/or be diminishing with time and institutional c
implemented."
Concurrent with the ·
officials and 4 communi
following questions w
• What is you
• Do you live h
• Are you familia
• Have you been
• What effects, if
communities?
cted interviews with 2 city
the dates of June 7 -8, 2007. The
idual:
era/I im • ession .of the project?
the si ?
ith PA activities at the site over the past years?
I · sed or displeased with clean-up actions?
iy, have site operations had on the surrounding
• Do you still have any concerns regarding EPA clean-up activities at the
site?
• Do you think you have been kept adequately informed about clean-up
activities at the site?
. • Are you aware of any events, incidents, or activities at the site such as
vandalism, trespassing, or emergency responses from local authorities?
• Is there someone else that you would like to recommend we contact for
more information?
• Do you have any suggestions that EPA can implement to improve
communication with the public?
17
• •
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
Overall, the citizens are pleased with the US EPA's clean-up efforts. Some
community members were concerned about some barrels that were left on the site, but
when reported to the US EPA the barrels were removed in December, 2006. There is
also concern about some type of film that appears on the run-off water in the ditches.
Even though this is a concern, they trust that the clean-up was successful. It appears
that the remedy is working as intended.
7.0 Technical Assessment
7.1 Question A: ts the remedy functioning as intended by the decision
documents?
The remedy is not functioning as intended by th decision documents because
institutionai controls have not been implemented; ho e current groundwater
remedial action, natural attenuation, is performing a ted. The 2000 ROD
Amendment states that it is expected that the groun inant levels will be
reduced by natural attenuation and will continue to stablished
remediation goal for benzene, ethylbenzene, and aph ess than 4 years. The .
natural attenuation for 1,2,4-trimethlybenzene iation goals in
groundwater in approximately 5 years for are aldwin Drive and less
than 15 years for the area south of Joe B w on the most recent data,
benzene, naphthalene, and 1,2,4-and , , -tr are the only
contaminants that have excee tion s within the past 5 years. Benzene,
however, was the only CO\A'f',.,,. a • e its remediation goal during the last
sampling event in Febr
O&M activities at th ite are • nducted by the US EPA's contractor, Black &
Veatch. The monitoring we pied and inspected during each groundwater
monitoring event. As stated valuation of Monitored Natural Attenuation at the
Potter's Pits Site, June 2000 ort, the 1992 ROD significantly overestimated the
scope and cost of the ground ater extraction remedy, with an estimated cost of
$7,000,000. Based on the new MNA groundwater remedy, the cost is estimated to be
$800,000. As stated by the US EPA, the estimated cost of O&M per year is $50,000.
Currently, no human or ecological exposure pathways exist to contaminated soil
or groundwater. In order for the remedy to be protective in the long-term, however,
restrictive covenants or other appropriate institutional controls must be implemented for
the Potter's Pits Site.
18
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
7.2 Question B: Are the exposure assumptions, toxicity data, clean-up
levels and remedial action objectives (RA Os) used at the time of the
remedy still valid?
The exposure assumptions, toxicity data, clean-up levels, and RAOs used at the
time of the remedy are still valid for the CO Cs. The chemical-specific ARARs (i.e.,
MCLs and the State Groundwater Standards) have not changed for the COCs from the
Remediation Goals given in the ROD Amendment. Currently, the land use at the Site
remains unchanged and no new human health or ecological routes of exposure have
been identified or modified in any way that would change the protectiveness of the
remedy.
As stated earlier in Section 4.1 Remedy Sele 2000 ROD Amendment
made two changes to the groundwater remediation the Site. First, the
remediation goal for benzene (5 ug/I) and naphthale /1) were changed to 1 ug/I
and 21 ug/I, respectively. The remediation goals for -zen 1 g/I) and naphthalene
(21 ug/I) are the State of North Carolina's Ground a e St . ards. Second, the
contaminants 1,2,4-trimethylbenzene and 1,3,5 . eth nzene are now included as
COCs. The remediation goal for both of thes ina is 60 ug/1. These changes
are still valid and protective of human hea h vir ment.
There have been n
affect the protectiven
the remedial action f
zone, and the remedi
however, institutional
discussed further in the
7.3
phy ..
II remediation goals were achieved during
• lion of contaminated soils in the saturated
nd ter continues to operate as designed;
t been implemented for the Site. This matter is
ecommendations section of this review.
any other information come to light that could call
e protectiveness of the remedy?
No additional information has come to light that could call into question the
protectiveness of the remedy.
7.4 Technical Assessment Summary
The US EPA has determined that natural attenuation at the Site is performing as
anticipated for groundwater. EPA needs to determine whether concentrations of
contaminated soils in the saturated zone are decreasing as a result of natural
attenuation and, based on its findings, select an appropriate remedy to address this
media of concern. The exposure assumptions, toxicity data, clean-up levels and RAOs
used at the time of the remedy are still valid for the COCs. There are no current
19
•
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
exposure routes to the groundwater and the remedy, in the short-term, is still protective
of human health and the environment. No other information has come to light that
would call into question the short-term protectiveness of the remedy. However, in order
for the remedy to be protective in the long-term, restrictive covenants or other
appropriate institutional controls must be implemented at the Site.
8.0 Issues
There is one issue that has been identified during this review.
1. Implement restrictive covenants or other appropriate institutional controls (ICs)
at the Site.
The 2000 ROD Amendment requires that ICs mented at the Site for the
purpose of limiting exposure to contaminated groun s explained in section 4.2,
the US EPA was unable to remove contaminated so aturated zone and, as a
result, ICs must be implemented to limit exposure to • • tam , t d soils in these areas
as well. Because contaminated soils in the satur eel e w not specifically
addressed as part of the MNA/institutional con et forth in the 2000 ROD
Amendment, some sort of remedy change (m • e to file or ESD) will be
needed to implement an IC for this media In S EPA (in consultation with
NC DENR) has determined that use re t the 2000 ROD Amendment
designed to prevent/control erosion ecessary. As a result, the
US EPA will prepare a note.Rl"Tt!< remove the erosion prevention/control and
institutional control requ·
at restrictive covenants and deed notices are the
most appropriate I Cs for ac I ving [ edial objectives for groundwater. Restrictive
covenants and deed notices • to be the most appropriate ICs for preventing
exposure to contaminated soi nee implemented, the ICs for these media will be
monitored and enforced by th US EPA and/or NC DENR until such time as clean-up
goals are reached. Listed below are several IC actions recommended by the US EPA
to be completed by the next Five-Year Review. Support for these recommendations
can be found in the IC Implementation Plan developed for the Site.
• Record deed notice entitled "Notice of Inactive Hazardous Substance or
Waste Disposal Site" on the properties that comprise the Site, if possible.
The purpose of the deed notice is to limit exposure to contaminated soil and
groundwater.
• Discuss with NC DENR appropriate language for restrictive covenants to be
placed on these properties. The purpose of the restrictive covenants is to
limit exposure to contaminated soil and groundwater.
20
(
Five-Year Review
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County, NC
• Negotiate restrictive covenants with owners of these properties. Get
necessary signatures and record restrictive covenants. If the owners of the
three properties that comprise the Site will not agree to implement restrictive
covenants on their parcels, other appropriate institutional controls will be
implemented.
9.0 Recommendations and Follow-up Actions
Table 6 lists the Recommendations and Follow-up Actions for the Potter's Pits
Site.
10.0 Protectiveness Statement
As stated in the 1992 Record of Decision (R 2000 ROD Amendment,
the goal of the Potter's Pits remedial action is to red levels of contamination
as to allow for unlimited use and unrestricted expos rs that natural
attenuation of groundwater is performing as antic· ate clean-up levels will
eventually be attained. The remedy at the Sit , ntly tects human health and the
environment because the main source of con min remediated through source
removal and no human or ecological exp ur ath st to contaminated
groundwater or soil in the short term. o ve the remedy to be protective
in the long-term, the followin s to b en: Implement restrictive covenants
or other appropriate institu · . t the Site.
11.0 Next Review
The r:iext Five-Year the Potter's Pits Site is required to be completed
within five years from the LJSIP.!;'MRegion 4 Superfund Division Director's (or his
designee) signature/approval e of this document.
21 .
i"· "· FIVE YEAR REVIEW FACT SHEET
POTTER'S SEPTIC TANK SERVICE PITS SITE
Sandy Creek, North Carolina
October 2002
What is the purpose of a Five-year Review?
The purpose of the review is to evaluate the implementation and performance of a remedy in order
to determine if the remedy is or will be protective of human health and the environment. The Five-
year review report identifies issues found during the review and recommendations to address them.
The 1992 Record of Decision selected Low Temperature Thermal Desorption to treat contamination in
soil and a pump-and-treat system to treat contamination in groundwater. Based upon additional
investigations conducted in 1999 and June 2000, plus additional data, it was determined that Monitored
Natural Attenuation would be implemented for groundwater instead of a-pump-and-treat system.
Whe11 should a Five-year Review be co11d11cted?
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead
agency shall review such action no less often than every five years after the initiation of the
.selected remedial action. (40 CFR §300.430(f)(4)(ii)]
Soil was treated March 1995 -June 1996 which removed contaminants. However, contaminants remain
in groundwater above safe drinking water standards. Because of this reason, a Five-year Review was
conducted based upon the above regulation.
Who co11d11cts the review at aft111d-fi11anced site?
EPA has the responsibility of either conducting the review or hiring a contractor or other agencies
(i.e., U.S. Army Corps of Engineers) to perform studies, conduct investigations, and/or develop
draft Five-Year Review reports.
The U.S. Army Corps of Engineers conducted the Review for this Site in April 2002. EPA reviewed and
commented on, and later approved the report.
In ge11eral, how was the assessment of the protective11ess of the remedy co11d11cted?
• The first step was to review all relevant documents, data and other information concerning the selected
remedies and all monitoring documents since the remedy was implemented to determine performance.
• Conducted interviews with site manager, contractor and personnel, State Superfund personnel, local
officials, and randomly selected residents.
• Conducted site inspection to determine if the remedies were functioning as intended; if the exposure
assumptions, toxicity dat,a, clean up levels and remedial action objectives are still valid; and has any
other information come to light that could question the protectiveness of the remedies.
• • ... Conducted..site inspection,to.:.visually confirm and·document conditions,of.the-remedyana.· •. : ...... ,: ........ , ....... · ,
surrounding area, reviewed expenses ofremedies, noted any outstanding issues, and listed any /
recommendations requiring follow-up.
• Prepared written Five-Year Review document dated August 2002 and submitted it to EPA for
review/approval.
What did the assessment reveal about the remedies?
L The remedial action at the Potter's Pits Site currently protects human health and the environment. The
main source of contamination was removed through the low temperature thermal desorption (LTTD)
treatment of the contaminated soil in 1996. Based on a final inspection of the Site by EPA and the
State of North Carolina Division of Superfund in 1999, the clean up goals for removal of contaminants
in soil established in the Record of Decision (ROD) and Remedial Design were met. The soil
treatment remedy considerably reduced contaminants in the groundwater so that there was no need to
pump and treat the groundwater. Even though the pump-and-treat remedy was originally selected in
the 1992 ROD, its implementation was not necessary to protect human health and the environment
based on additional data. The geophysical and/or hydrological data suggested a strong likelihood that
attenuation processes were occurring naturally, and they would assure attainment of the remedial goals
in an acceptable time frame. Therefore, the monitored natural attenuation and institutional control
remedy was implemented.
2. The selection of monitored natural attenuation and institutional conirols as the remedy is still valid as
there have not been any changes to the original assumptions as stated in the Amended Record of
Decision. Based on the review, all appropriate measures and procedures were utilized at the time of
the remedial action and continue to be in effect.
3. Based on validated information provided in the documentation that was reviewed, there is no
information to date that significantly questions the protectiveness of the remedy. Data collected since
the conclusion of soil treatment supports monitored natural atteniiation as the preferred method of
groundwater remediation at this Site.
Wltat were the reco111me11datio11s of the Five-Year Review?
L EPA needs to coordinate with the landowners and the North Carolina Attorney General's office to
implement the institutional controls proposed in the Record of Decision and the Amended Record of
Decision because these actions have not been implemented. The controls consist ofrestrictive
___ co.venants_and deed rec_ordation for the site Jots as related to groundw,!ter. The PIQROsed cont~r~o~ls'-----
consist of restriction of ground disturbing activities to no deeper than 25 feet below the ground
surface, and prohibit installation of potable water wells in the site area. Once implemented, the
institutional controls should be reviewed during the next five-year review because the Sandy Creek
area may be developing a community-wide water supply system in the near future.
2. Ensure that all monitoring wells are secured and locked to prevent tampering and damage.
The remedy at the Potter's Septic Tank Service Pits Site currently protects human health and the
environment because the soil remedy is complete and the monitored natural attenuation remediation of
groundwater is continuing. However, in order for the remedy to be protective in the long-term,
implementation of institutional controls should occur.
' . ,_ '-'----.
• •
How s!tould tlte community be involved?
Activities should include notifying the public that the Five-Year Review will be conducted,
contact citizens for their input,'notify the public that the Review has been completed, and place a
copy of the Review in the site information repository.
Residents, local officials, NC State Superfund staff and other interested people were contacted and asked
questions concerning EPA's performance, if they felt comfortable with the chosen/implemented remedies,
and if they had any remaining concerns about the Site. A display ad was placed in the local newspaper to
notify the public that the Five-Year Review would be conducted, and a display ad was placed in the local
newspaper that the Review had been completed. A copy of the Five-Year Review was placed in the
Information Repository located in the Leland Public Library, Leland, N.C. A fact sheet v-:as prepared
summarizing information in the Five-Year Review and mailed to people on the Site mailing list.
Will anot!ter review be conducted?
The next Five-year Review is scheduled to occur in 2007.
Have questions?
If you have technical questions about the Five-Year Review document, please contact Beverly Hudson,
EPA Remedial Project Manager at 1-800-435-9233 or 404-562-8816. If you want copies of Site fact
sheets or general Site information, please contact Diane Barrett, Community Involvement Coordinator at
1-800-435-9233 or 404-562-8489.
\Vant to read documents?
Copies of all documents developed during the investigation and remediation of this Site have been placed
in the Infonnation Repository located in the Leland Public Library in Leland, North Carolina, as well as
the EPA Record Center in Atlanta, GA.
--------------------------------------------------------------------------------------------------------
Address change/correction/deletion?
If you want to chari.ge/correct/deiete your name from the Potter's Septic Tank Service Pits Site mailing
list, please complete the form below and return to Diane Barrett, Community Involvement Coordinator,
USEPA, 61 Forsyth Street, SW, 10th Floor Waste Management Division, Atlanta, GA 30303.
• I . , .
Name------------------------------~------
Address -----------------------------------
Cit, State, Zip Code-----------------'---'-------------
Change □ Correction D Deletion D ·
Thanks!
• • ·.-• ....... , ... _,,_,.,
U.S. Environmental Protection Agency North Site Management Branch \,AP,;
61 Forsyth Street, SW Diane Barrett, Community Involvement Coordinator ;:-)',
Atlanta, Georgia 30303-8960 Beverly Hudson, Site Remedial Project Manager ( '< '9 N0'/O7'O2
Official Business
Penalty for Private Use $300
NOV 1 3 2002
S/F POTR 76
MR. NILE TESTERMAN, PROJECT MGR.
N.C. SUPERFUND SECTION
NC DEPT. OF ENVIRONMENT & NATURAL RESOURCES
1601 MAIL SERVICE CENTER
RALEIGH NC 27699-1601
• •• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
October 9, 2002
Mr. Nile Testerman
North Carolina Department of Environment
and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
Dear Mr. Testerman:
sr~
Enclosed is a final copy of the Five-Year Review Report for
the Potter's Septic Tank Service Pits site. If you have any
questions regarding the report, please call me at 404 562-8816.
Enclosure:
Sincerely,
~J-./luJ--
Beverly T. Hudson, RPM
Waste Management Division
Internet Address (URL} • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable OB Based Inks on Recycled Paper (Minimum 30% Postconsumer)
"
Director, Waste Division
U.S. EPA Region 4
• Fivt-Ytar Rtvitw
Potter's Srptic Tank Str71ift Pili, Santfy Crttk, NC
Five-Year Review Report
First Five-Year Review Report
For
Potter's Septic Tank Service Pits
Sandy Creek
Brunswick County, North Carolina
August 2002
Prepared By:
US Army Corps of Engineers
Wilmington District
Wilmington, North Carolina
Prepared For:
Region 4
U.S. Environmental Protection Agency
Atlanta, Georgia
• • { Five-Year Revitw
Potter's Septic Tank Servile Pits, Sanrfy Cruk, NC
Five-Year Review Report
Table of Contents
List of Acronyms ...................................................................................................................... iii
Executive Summary············································································································~···· iv
Five-Year Rcvie,v Summary Form ........................................................................................... vi
I. Introduction ........................................................................................................................... 1
II. Site Chronololgy ..................................................... ,: ........................................................... 2
III. Background ....................................................................................................................... 3
,\. Physical Characteristics., ................................................................................................................... 3
fl. Land and Resource Use ..................................................................................................................... 3
C. History of Contamination ............................ , .................................................................................... 4
D. Initial Response .................................................................................................................................. 6
IV. Remedial Actions ............................................................................................................... 6
A. Remedy Selection ............................................................................................................................... 6
B. Remedy Implementation ................................................................................................................... 9
C. Progress Since the Last Five-Year Review ................................................................................... 13
V. Five-Year Review Process .................................................................................................. 13
VI. Five-Year Review Findings ............................................................................................... 13
A Interviews .......................................................................................................................................... 13
B. Site Inspection ...................................................... : ........................................................................... 14
C. i\Rl\R Review ................................................................................................................................... 16
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics.: ............ 16
E. Data Review ...................................................................................................................................... 16
VII. Assessment ........................................ , ............................................................................ 20
Question A: Is the remedy functioning as intended by the decision documents? ...................... 20
Question B: Are the assumptions used at the time of the remedy selection still valid? ............. 20
Question C: Has any information come to light that could call into question the protectiveness
of the remedy? ........................................................................................................................................ 20
I
VIII. Issues ............................................................................................................................. 21
IX. Recommendations and Follow-up Actions .............................. : ....................................... 21
X. Protectiveness Statements ........................................................................ .1 •••••••••••••••.•••••••• 22
XI. Next Review ............................. : ....................................................................................... 22
List of Figures
•
Five-Ymr Rtvie/1)
Potter's Septit" Tank Servit'e Pits, Sand.Jr Creek, NC
' Figure 1. General Location ............................................................................................................................ 4
Figure 2. Specific Site Location ...................................................................................................................... 5
Figure 3. Monitoring Well Locations ... : ....................................................................................................... 11
Figure 4. New Monitoring Well Locations ......................................................................... , ....................... 12
['igure 5. Maximum Benzene and Ethylbenzenc Concentrations in all Potter's Pits Groundwater
Monitoring Wells 1984 -1993 .............................................................................................................. 19
Figure 6. _.Ma~imum Benzene and Ethylbcnzcne Concentrations in all Potter's PitsfGround\vatcr
J\lomtortng Wells 1996 -2002 .............................................................................................................. 19
List of Tables
Table 1. Chronology of Events ..................................................................................... 1 ................................ 2
Table 2. Soil Clean-up Standards ................................................................................................................... 8
Table 3. Groundwater Clean-up Standards ......................... : ........................................................................ 8
Table 4. Revised Groundwater Clean-up Standards (AROD) .................................................................. 9
Table 5. Pre-and Post-Excavation Soil Concentration Data .................................................................. 17
Table 6. Sampling Efforts by Well Number .............................................................................................. 18
Table 7. Recommendations and Follow-up Actions ................................................................................. 21
u
• fi'w-Year Rtvieul
Poller's Septic Tank Servfre Pits, Santfy Crrek, NC
List of Acronyms
ARARs Applicable or Relevant and Appropriate Requirements
· AROD Addendum to the Record of Decision
BTEX Benzene, Toluene, Ethylbenzene, and Xylenes
CENWHO-HX-G Corps of Engineers Hazardous, Toxic and Radioactive Waste Center of
CERCLA
CERCLIS
Expertise
Comprehensive Environmental Response, Compensation, and Liability Act
Comprehensive Environmental Response, Compensation, and Liability
Information System
CESA W-TS-PE Wilmington District, Corps of Engineers Environmental Resources
CFR
EPA
FS
JAG
IDW
Kg
L
LTTD
MNA
NCP
NPL
PAHs
ppb
ppm
PRP
RA
RD
RI
ROD
RPM
SARA
SESD
µg
USACE
voe
WasteLAN
Section /
Code of Federal Regulations
United States Environmental Protection Agency
Feasibility Study
lnteragency Agreement
Investigation Derived Waste
Kilogram
Liter
Low Temperature Thermal Desorption
Monitored Natural Attenuation
National Oil and Hazardous Substances.Pollution Contingency Plan
National Priorities List
Polynuclear Aromatic Hydrocarbons
Parts Per Billion
Parts Per Million
Potentially Responsible Party
Remedial Action
Remedial Design
Remedial Investigation
Record of Decision
Remedial Project Manager
Superfund Amendments and Reauthorization Act of 1986
Science and Ecosystems Support Division
Microgram
United States Army Corps of Engineers
Volatile Organic Compound
The Regional database related to CERCLI S
ill
8 •
/ Five-Year Review
Pol!er's Septic Tank Servit:e Pi!!, Sa11rfy Creek. NC
Executive Summary
This report documents the first five-year statutory review of the Natio~al Priorities List
(NPL) site NCD98 I 023260. The site, referred to as Potter's Septic Tank Service Pits, is a
former septic sludge disposal pit site located in Sandy Creek, Brunswick County, North Carolina.
The site is approximately five acres in size. Contaminants of concern associated with
groundwater at the site are volatile organic compounds (VOCs) including benzene and xylene,
phenols and petroleum compounds. There was also soil contamination involving heavy metals,
chloroform, phenols, VOCs and other petroleum compounds. These contaminants are the result
of disposal of waste oil, creosote, and septic sludge in unlined pits by Potter's Septic Tank
Service from I 969 to I 976.
Contamination was traced back to the pits as the result of investigation by the U.S. Coast
Guard into an oil spill in I 976. As a result of the spill, the Coast Guard cleaned up
approximately 20,000 gallons of oil from the Chinnis and Rattlesnake Branches. Mr. Otto
Skipper subsequently pumped an additional 20,000 gallons of oil from the pits and transported
the waste to Fort Bragg Military Reservation in Fayetteville, North Carolina. During the same
time frame, about 150 dump truck loads of oil sludge and oil stained soil were removed from the
site and disposed of in the Brunswick County Landfill in Leland, North Carolina.
Between 1982 and 1983, the property surrounding the site was developed and subdivided
into one and two acre residential lots. In July 1983, the owner ofa portion of the site property
found waste materials buried in their yard. The State of North Carolina sampled soil and
groundwater, analysis of which confirmed the presence of contamination, resulting in the
condemnation of the property owner's potable water well. Subsequent soil and groundwater
sampling identified the following organic contaminants at the Site: Benzene, toluene,
ethylbenzene, xylenes (BTEX), and polynuclear aromatic hydrocarbons (PAH's). From soils
data, BTEX levels were in excess of 1,600,000 parts per billion (ppb), PAH concentrations
exceeded 43,000 ppb, and naphthalene levels were as high as 58,000 ppb. Inorganic
contaminants of concern were lead, chromium and zinc. Maximum soil lead, chromium, and
· zinc concentrations were 1250 parts per million (ppm), 170 ppm and 3,300 ppm, respectively.
In March 1984, EPA conducted an emergency removal action to remove the soil source
of contamination. Approximately 1,770 tons of contaminated soil were removed from the site
and hauled to a hazardous waste landfill in Pinewood, South Carolina. Nine groundwater-
monitoring wells were installed and sampled as an adjunct to the removal action.
After conducting the Remedial Investigation and Feasibility Study, EPA signed a Record
of Decision (ROD) for remediation of contaminated soils and groundwater on Apgust 5, 1992.
The ROD selected Low Temperature Thermal Desorption as the preferred source remediation
and Pump-and-Treat for the groundwater remediation. Soil source remediation activities took
place between March 1995 and June 1996. Following source remediation, the EPA Region 4
Science and Ecosystems Support Division (SESD) conducted additional site investigations
during 1999 and June 2000. Based on those investigations, an evaluation repo,rt, and a
Feasibility Study Addendum, an Amended Record of Decision (AROD) selecting monitored
natural attenuation (MNA) for remediation of groundwater contamination was signed September
• •
Five-Year &view
Poller! Septic Tank Service P,ls, Sanrfy Crrek, NC
I .
27, 2000. The clean-up standards for the AROD are as follow: Benzene - I µg/L; Ethylbenzene
-29 µg/L; Naphthalene -21 µg/L; 1,2,4 and 1,3,5 Trimethylbenzene -60 µg/L (total). ·
· Since implementation of the monitored natural attenuation remediation of groundwater
contaminants at the site, there have been two sampling events of monitoring wblls on the site -
one in Octoberof2001 and the other in March of 2002. The March sampling coincided with
installation of additional monitoring wells suggested in the September 2000, Supplemental
Evaluation of Monitored Natural Allenuation at the Poller 's Pits Site, Sandy Creek, North
Carolina.
Two issues were identified during the review process. None of these issues affect the
assessment of the performance of the remedy. However, each should be addressed before the
next five-year review. The issues are described as follows:
I: Institutional controls for the site as proposed in the documents of record have not been
implemented. The EPA should coordinate with the site property owner(s) and the State of North
Carolina to implement the proposed institutional controls.
2. Monitoring wells need to be properly secured and locked to prevent tampering and
damage.
The remedial actions at the Potter's Pits site currently protect human health and the
environment. The soil remediation for the site has been completed, and the monitored natural
attenuation remediation of the groundwater contamination including monitoring is continuing.
The 1996 soil remediation clearly had the effect of reducing groundwater contarpinant
concentrations. The groundwater contamination trends attributable to the MNAi remedy cannot
presently be determined. The trends of contaminant concentrations in groundwater are difficult
to discern because of frequent changes in the sampling program. To ensure long-terrn
protectiveness of the selected site remedy, implementation of institutional controls should occur.
\'
• •
Five-Year &view
Poller's Septic Tank Servfre Pits, Sanrfy Creek, NC
Five-Year Review Summary Form
Five-Year Review Summary Form
Site Identification
Site Name: Potter's Septic Tank Service Pits
EPA ID: NCD98 I 023260
Region: 4 I State: NC I Citv/Countv: Sandv Creek/Brunswick
--;-:---:;: ., ·\ .. ':<·:'.':.:·-.'•.·:·•·. :. .. '• : : .. ;_:i'·i-\ ·;,:,,r':··~/.f~~·s1TE~' STA TUS:'li·,\"-''.ft?ii:}2;;~ifJif,¥X4\'.-t~?i'~$.t~h1)~Y:t;?!~'ftM~J~frrr:Z{½Xf~; :,: : . . , ~\ -;:. ,_,
NPL status: ✓ Final □ Deleted □ Other:
Remediation Status: □ Under Construction ✓ Operating □ Comolete
Multinle OUs?* □ YES ✓ NO I Construction Comnletion Date: Sentember 27, 2000
Has site been nut into reuse? ✓ NO
].:J:l-\-~.:),.~_-~;i. . :f; ,:" :. > -:•.:•:. ;;'. :· /":. .)~·t,: ·1/.Jfi'REVIEW-STATUSi\~1\}W~t~f~.:~t~\'.j;ff_fJ!}i!{tJ;:,~~\~li~tl~ftf~~)1i~
Reviewing a<'encv: ✓ EPA □ State □ Other:
Author name: Stacv Samuelson
Author title: Biologist
I
Author affiliation: USACE, Wilmington
District
Review ueriod:** 4/02-4/07
Date(s) of site insnection: Aoril 12,2002 I
Type of review:*** ✓ Statutory
□ Policy (□ Post-SARA o Pre-SARA □ NPL-Removal only
□ Non-NPL Remedial Action Site 0 NPL State/Tribe-lead
O Regional Discretion)
Review number: ✓ I /first) □ 2 (second) □ 3 (third) □ Other (suecifv)
Triggering action:****
□ Actual RA On-site initiation by PRP ✓ Actual RA start at OU# I
□ Construction completion □ Previous Five-Year Re~iew Report
□ Other (specify)
Triooerin!! action date: Seotember 27, 2000
Due date-(five years after tri!!!!ering action date): September 2 7, 2005
* "Ou•· refers to operable unit. ·
** Review period should correspond to the actual start and end dates of the fiv6-year review in
Waste LAN.
*** See Chapter I, Section 1.2 of EPA 540-R-0 1-007, Final June 200 I for further explanation.
**** See Chapter I, Section 1.3 of EPA 540-R-0 I -007, Final June 200 I for further explanation .
•
VI
• • j Five-Year &uiew
Poller's Septic Ta11k Servi e Pits, Sanrfy Crtek, NC
Five-Year Review Summarv Form
. Issues: I I. Institutional controls for the site as proposed in the documents of record have not been
implemented.
2. Monitoring wells need to be properly secured to prevent tamnerinQ.
Recommendations and Follow-up Actions:
I. The EPA needs to coordinate with the landowner and the State of North Carolina to
emplace the Institutional Controls proposed in the ROD and AROD.
2. Ensure that all monitoring wells are secured and locked to prevent tampering and
damage.
Protectiveness Statement(s):
The remedy at the Potter's Pits Site currently protects human health and the environment
because the soil remedy is complete and the monitored natural attenuation remediation of
groundwater is continuing. However, in order for the remedy to be protective in the long-terrn,
implementation of institutional controls should occur.
VII
•
I. INTRODUCTION
• five-Year &view
Pol/er's Septic Tank Service Pili, Sand_)• Creek, NC
FIVE-YEAR REVIEW REPORT I
The United States Environmental Protection Agency (EPA) Region 4 h,as completed a
five-year review of remedial actions implemented at the Potter's Septic Tank Service Pits site in
Sandy Creek, Brunswick County, North Carolina. The United States Army Corps of Engineers
(USACE) conducted and provided technical assistance and analysis for the five-year review.
The Environmental Resources Section, Planning and Environmental Branch, Technical Services
Division of the Wilmington District, Wilmington, North Carolina provided the USACE lead for
this review. The review was accomplished under EPA Work Authorization Form for
lnteragency Agreement (JAG) Number DW96945884. The Wilmington District was supported
in the conduct of the review by the USACE Hazardous, Toxic and Radioactive Waste Center of
Expertise (CENWO-HX-G) located at the Omaha District, Nebraska. This review was
conducted from March 2002 through August 2002. The report documents the results of that
review.
The purpose of five-year reviews is to determine whether the remedy at a site is or is
expected to be protective of human health and the environment. The methods, findings, and
conclusions of reviews are documented in five-year review reports. In addition, five-year review
reports identify issues found during the review, if any, and recommendations to address them.
This review is a statutory review. EPA must implement five-year review consistent with
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and
the National Oil and Hazardous Substance Contingency Plan (NCP). CERCLA § 121(c), as
amended states:
1 fthe President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often that each five years after the initiation of such remedial action to
assure that human health and the environment are being protected by t?e remedial action
being implemented.
The NCP part 300.430(1)(4)(ii) of the Code of Federal Regulations (CFR) states:
1 fa remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
This is the first five-year review of the Potter's Septic Tank Service Pits site. The Site
was originally identified as requiring a "policy" five-year review, which must occur within 5
years after completion of construction. Completion of construction, as designated by signature
of the Preliminary Close-Out Report occurred on September 27, 2000.
However, also in fiscal year 2000, EPA amended the Record of Decision for this Site,
and concluded that they would likely leave some contamination on the Site at levels that
exceeded unrestricted uses. The EPA also concluded that institutional controls would be needed.
• • Five-Year R!vitw
Potler's Septic Ta11k Servia Pits, Santfy Crrek, NC
With this decision, the five-year review became a "statutory" review, required within 5
years of start of on-site remedial action (the Remedial Action Start date is September 30, 1994 ).
,· Therefore the five-year review report became technically overdue on the date of the fiscal year
2000 ROD amendment. The next five-year review will be due 5 years after completion of this
five-year review.
This review will be placed in the EPA site files and local repository for the Potter's
Septic Tank Service Pits site. The local repository is located at the Leland Public Library, 487
Village Road, Leland, North Carolina 28451.
II. SITE CHRONOLOGY
Table I lists the chronology for selected events for the Potter's Septic Tank Service Pits
site, as shown below.
Table I: Chronology of Events
EVENT . '. ,', " ... , . DATE",,.,::'~-
Skipper Family uses the site for disposal of waste petroleum waste and septic tank sludge in unlined 1969 to 1976
oils.
Unlined pit failure allowed 20,000 gallons of oil to flow into the Chinnis Branch and Rattlesnake 1976
Branch.
Removal of20,000 gallons of oil from site to Fort Bragg Military Reservation in Fayetteville, North 1976
Carolina.
Site nurchased for residential devclonment bv Investment Management Cornnration. 1980
Site owners discovered waste materials in their yard. 1983
State of North Carolina investigation of soil and groundwater confirming presence of contaminants July. I 983
resultin12. in condemnation of the site owners well.
EPA and Re1i:ion IV Field lnvesti2ation Team conducted survevs to ddineate extent of contamination. , Sentcmber, 1983
EPA Otncc of Emergency and Remedial Response initiated an immediate Removal Action, removing I March 21, 1984 to
1,770 tons of oily sludge and contaminated soils to a hazardous waste landfill in Pinewood, South April 2, I 984
Carolina.
EPA·Rei;i:ion IV nro""scs a 1noundwatcr monitorini;i: nlan to determine threats to groundwater sources. Mav, 1984
Preliminarv Assessment of site conducted revealing soil and water contamination. Sentember, 1987
Site added to National Priorities List (NPL). March 31. 1989
Remedial lnvestiization (Ill) Rennrt comolc1ed. I December, 1991
Feasibilitv Studv <FS\ comnleted Auoust 5, 1992
Record of Decision (ROD) siP-nature. AUP'USt 5, I 992
Contract award for soil source remediation. November, 1994
Mobilization for soil treatment. March, 1995
Explanation of Significant Difference (ESD) changing lead remedial level goal from 25 ppm to 400 February 9, 1996
nnm.
Soil excavation and treatment comnlete. Anril, 1996
Pre•final insnection of soil remediation bv Rechtcl June, 1996
Final insocction of soil remediation by EPA and State of North Carolina. June! I. 1999
Feasibility Study Addendum to evaluate Monitored Natural Attenuation and Institutional Contr0ls as a August 11, 2000
rcmedv for 2roundwater contamination.
Amended Record ofDecision.(AROD) signature. Sentcmber 27, 2000
Preliminarv Close•Out Renart Sectember 27, 2000
Field investigation including ootable water well samnlinR. October 29. 2001
Follow•uo ""table water well samnliniz December 17, 2001
Additional monitorim~ well installation and samnli1111. March. 2002
Site insncction for the first live•vear review. Aoril 12,2002
2
III. BACKGROUND
A. Physical Characteristics
• F)pe-Year RtPiew
Potter's Sep!it' Tank Sa'Vice Pits, Sa111y Crrek, NC
The Potter's Septic Tank Service Pits Site is located in a rural, but developing section of
Brunswick County, North Carolina, in a residential development known as the Town of Sandy
Creek. The town is located off of U.S. Highway 74/76 to the west of Maco, North Carolina
(Figure I). Sandy Creek consists of one to two acre lots, each with an individual domestic water
well. The site consists mainly of Lots 85, 86 and 87 of the Sandy Creek development located to
the east of Grainger Circle and north of Joe Baldwin Drive. In 2000, approximately 70 of 150
residential lots were occupied within the Sandy Creek area.
The Potter's Pits Site was originally divided by EPA into three study arclas, Areas I and 3
are located in the Sandy Creek residential area, and Area 2 was located about 1.5 miles to the
north across U.S. Highway 74/76 (Figure 2). Area I consists of the Potter's Pits Site, whereas
Areas 2 and 3 were identified during preliminary investigations as having potentially been waste
disposal areas. Area 3 was removed from consideration during the Remedial Investigation (RI)
phase, and Area 2 was removed when investigation revealed no information dr evidence of
disposal activities.
The Potter's Pits Site extends from an upland area to a lo.w-lying wetland bordering
Chinnis Branch on the east. The site has topology typical of the Atlantic coastal plain
physiographic region, with shallow water tables and low topographic relief. Soils in the area are
classified as Baymeade fine sand and Foreston loamy fine sand types that overlay a limestone or
calcareous sandstone basement member. There is also an intermittent clay zone at a level of 30
to 40 feet that tends to divide the shallow groundwater aquifer from the deeper aquifer in the
area. Drainage from the site is to the northeast toward the Chinnis Branch, which flows into
Rattlesnake Branch.
B. Land and Resource Use
Current land use of the area is rural residential in nature. Development of the area by
Investment Management Corporation created one and two acre lots, each supplied by its own
well for potable water. In 2000, approximately 70 of 150 lots were inhabited with single-family
dwellings. Based on current levels of development of the area, it ·is not foreseen that there will
be ·any major change in land-use in the future.
3
Figure I. General Location
C. History of Contamination
• t' ... "ive-Year Review
Pol!erf Septic Tank Service Pits, Sandy Cruk, NC
From 1969 to 1976, the Skipper family owned the property and operated sludge hauling
and oil spill cleanup companies in the area. Waste disposal pits were developed in and around
the Sandy Creek area. Waste petroleum and septic tank sludge was disposed of in shallow
unlined pits or by spreading material directly on the land surface. Records do not show the
composition of the materials disposed of at the site.
In August of I 976, an unlined pit in the site area failed allowing approximately 20,000
gallons of oil to escape. The spill flowed into Chinnis Branch and then into Rattlesnake Branch.
The United States Coast Guard, responding pursuant to Section 311 of the Clean Water Act, as
amended, cleaned up the spilled oil from Rattlesnake Branch and traced the source back to the
Potter's Pits Site. '
After the August 1976 spill, Mr. Otto Skipper pumped approximately 20,000 gallons of
oil from the pits and transported the waste to Fort Bragg Military Reservation in Fayetteville,
North Carolina. At the same time, about 150 dump truck loads of oil sludge and oil stained dirt
were removed and disposed of in the Brunswick County Landfill in Leland, North Carolina.
Additional oil sludge that could not be pumped was mixed with sand and buried on site.
Documentation of the actual amounts or composition of the material disposed of in the landfill
has not been found in records related to the site.
4
S. Location 2 Specific ite Figure ·
m Location of Areas 1 and J
Area 1
5
c·pe-Year Rtuien,
, I c-'C P. Sa11dy Crrek. 1 , . T. k S rn•itr tit, . Potter S S rphr an
Joe Bald~'.!_g!i~:l
Not To Scale
• • Five-Yrar lvview
Potler's Septi~' Ta11k Service ?1/1, Sanr!y Creek, NC
The property surrounding the site was developed and subdivided into one and two acre·
residential lots between 1982 and 1983. In July 1983, the owners of the property found waste
materials buried in their yard. The State of North Carolina sampled soil and groundwater,
: analysis of which confirmed presence of contamination, resulting in the condemnation of the Site
owner's water well. Subsequent soil and groundwater sampling identified the following organic
contaminants at the Site: Benzene, toluene, ethylbenzene, xylenes (BTEX), and polynuclear
aromatic hydrocarbons (PAH's). From soils data, BTEX levels were in excess of 1,600,000
parts per billion (ppb), PAH concentrations exceeded 43,000 ppb, and naphthalene levels ranged
as high as 58,000 ppb. Inorganic contaminants of concern were lead, chromium and zinc.
Maximum soil lead, chromium and zinc concentrations were 1,250 parts per million (ppm), 170
ppm and 3,300 ppm, respectively.
D. Initial Response
After the spill event in August of 1976, the Skippers were fined for un-permitted waste
disposal, but no further action was taken by the State of North Carolina or Brunswick County
officials.
In July 1983, a property owner living on the primary site area discovered contaminated
materials in his yard. As a result of the discovery, environmental investigatiohs of the site
began. Initial soil and groundwater testing by the State resulted in the condemnation of the site
owner's potable water well due to unacceptable levels of benzene. Further groundwater and soil
sampling was conducted by EPA to delineate the extent of contamination and also to test water
wells of residences throughout the area.
In March 1984, EPA conducted an emergency removal action to remove the soil source
of contamination. Approximately I, 770 tons of contaminated soi I were removed from the site
and hauled to a hazardous waste landfill in Pinewood, South Carolina. Nine groundwater
monitoring wells were installed and sampled as an adjunct to the removal action.
IV. REMEDIAL ACTIONS
A. Remedy Selection
The remedial actions in the Record of Decision (ROD) dated August 5, 1992, provided
for remediation of contaminated soils and groundwater. The remedial actions identified in the
ROD were as follows:
Grotmdwaler
The groundwater remedy was targeted at removal of site-related contaminants in the
groundwater through groundwater extraction and on-site treatment by chemical means and air
stripping. The following activities were identified as being associated with this alternative:
♦ Contaminated groundwater would be extracted from within the plume via extraction
well(s) and piped to an on-site, aboveground treatment facility.
6
Soils
• • f-,JJ!e. Year Ivvitw
Potter's Septit' Tank Service Pits, Sanrfy Creek, NC
♦ Treatment would consist of air stripping and chemical treatment configured in a
·'treatment train" where the air stripping will be used to remove the VOC's and the
chemical treatment (precipitation, flocculation, and filtration) would be used to remove
heavy metals.
♦ Final discharge of the effluent would be to Chinnis Branch, with parameters meeting
the substantive requirements of the National Pollutant Discharge Elimination System.
♦ Continued analytical monitoring of contaminants in groundwater.
The remedy for contaminated soils had the intent of permanently removing
contamination in the soil through treatment. The selected alternative involves Low Temperature
Thermal Desorption (L ITO). The following activities were identified as being associated with
this alternative:
♦ The current residents of the site would be relocated before remedial actions proceeded.
♦ Excavation of all soils exceeding cleanup standards identified in the ROD.
♦ Treatment of the excavated soils on-site using the ex-situ thermal desorption process.
♦ Treatment of the concentrated organic contaminants, a by-product of1thermal
desorption, which would be vendor dependent.
♦ Sampling and analysis of the treated soils to insure efficacy of the treatment process.
♦ Appropriate disposal of soils not adequately treated by the L TTD process.
♦ Backfill of excavated areas with treated soils, regrading of site and revegetation with
native grasses.
For each of the selected remedies, there were contingency measures to respond to the
potential of failure of the remedy to attain stated clean-up goals. Briefly, the contingency
measures for groundwater included long-term low level pumping and institutional controls for
restriction of access to portions of the aquifer remaining above health-based standards. For soils,
the contingency measure consisted of off-site disposal of contaminated materials. The
contingency measures are fully elaborated in the ROD (EPA, 1992). Contingency measures
were not implemented during the remedial action or after conclusion of the soil remediation.
7
' • Five-Year Rtvieiv
Polter! Septic Tank Servia Pili, Sa11rjy Creek, NC
Tables 2 and 3 show the clean-up standards for soil and groundwater under the ROD.
Table 2. Soil Clean-Up Standards
Soil Clean-Up Standards
Contaminant Clean-un Standard
Benzene .Oto nnm
Toluene 3.4 nnrn
Ethyl benzene .235 nnm
Xvlenes 3.5 nnm
Naphthalene 1.8 nnm
• Carcino!!enic PAHs .01 I nnm
Lead 25 nnm
Chromium 97.2 nnm
• Zinc 122 nnm
• Note: These standards will be applied to the top foot of soil only.
Table 3. Groundwater Clean-Up Standards
Groundwater Clean-Up Standards
Contaminant Clean-Up Standard
Benzene 5 onb
Toluene 1,000 nnb
Ethyl benzene 29 nob
Xylenes 400 nnb
Naohthalene 30 nob
Chromium 50 onb
Lead 15 nnb
The L TTD soils remediation was completed in June 1996. Site restoration was conducted
from 1996 to 1999. A final inspection by EPA and the State of North Carolina Division of
Superfund occurred on June 11, 1999. The EPA Science and Ecosystems Support Division
(SESD) conducted additional site investigations during 1999 and June of 2000. These studies
supported the finding that soil removal and treatment has reduced the contaminant source.
Based on results of the additional sampling and a feasibility study completed in June 2000, ·
to evaluate monitored natural attenuation (MNA) of groundwater contamination and a
supplemental report dated September 5, 2000, EPA issued an Amended Record of Decision
(AROD) September 27, 2000. The AROD addresses implementation of MNA and Institutional
Controls as the preferred alternative for remediation of groundwater contamination. The
components of the monitored natural attenuation and institutional controls alternative included
the following: I
♦ Groundwater monitoring program to monitor Volatile Organic Compound (VOC)
concentration and migration pathways.
8
• Five-Year Rtview
Po!te-ri StjJ/ic Tank Service Pits, Santf)· Creek, NC
♦ Periodic (short and long-term) sampling and analysis of groundwater to determine if
contaminants have degraded or migrated.
♦ Installation of seven deep zone and five shallow zone monitoring wells/to aid in
monitoring efforts.
♦ Implementation of Institutional Controls via deed recordation and restriction of use of
specific areas of properties overlying impacted groundwater.
The MNA alternative was·selected due to its comparable effectiveness to;the pump and
treat method selected in the original ROD for an overall reduced cost for the life of the remedial
action. Table 4 shows the groundwater cleanup standards of the AROD. Metals of concern (lead
and chromium), in the original ROD have been retained, although evidence shows that the
groundwater concentrations of these metals have decreased over time to levels below the ROD
groundwater clean-up goals or were not actually present as significant concentrations of mobile
phase contamination when they were detected.
Table 4. Revised Groundwater Clean-Up Standards (AROD)
Groundwater Clean-Up Standards (AROD)
Contaminant Clean-Up Standard
Benzene I u2/L
Ethvlbenzene 29 ,rn/L
Naphthalene 21 u2/L
1,2,4 and 1,3,5 Trimethvlbenzene 60 11<>/L (total\
Toluene 1,000 Ul!/L
Xylenes 400 u2/L
Chromium 50 u11/L
Lead 15 u2/L
The changes in the clean-up standards for benzene and naphthalene reflc,ct changes in
drinking water stand_ards in North Carolina. The Federal standard for benzene i$ 5 µg/L and the
change represe·nted in Table 4 reflects the more stringent North Carolina standard. For
naphthalene, the original clean-up standard was 30 µg/L with the change reflected in Table 4
occurring due to a change in the State Standard. The standard for 1,2,4 and I ,3,5
Trimethylbenzene was determined by risk analysis in the Supplemental Evaluation of Monitored
Natural Attenuation at the Potter's Pits Site, Sandy Creek, North Carolina (EPA, 2000).
B. Remedy Implementation
In May 1984, following the Removal Action conducted from March 2 I, 1984 to April 2,
1984, EPA Region 4 implemented a groundwater monitoring plan to determine whether the site
presented a danger to groundwater resources or not. Subsequent installation and sampling of
nine monitoring wells showed high concentrations of benzene, toluene, and xylenes (BETX) in
some of the samples. The State of North Carolina re-sampled the wells in 1988, with analysis
for volatile organics, phenols, priority metals, and several nutrients. Phenols and BETX were the
primary contaminants found. Additionally, the 1988 data indicated that one of the "deep" wells
9
Five-Year &view
Poller! Septic Tank Service Pits, Sanr!J Creek, NC
had low-level benzene, cthylbenzene, and xylenes contamination, which would indicate that the
"deep" aquifer had been affected.
As a result of the site investigation, the site was placed on the National Priorities List
(NPL) and a Remedial Investigation and Feasibility Study were begun under Superfund
authorities. The Remedial Investigation was completed by Ebasco Services under contract to
EPA Region 4 between 1989 and 1991. The Feasibility Study process coincided with the
Remedial Investigation and was completed on August 5, 1992 with the signing of the ROD.
Figure 3, developed by Weston as part of the Remedial Investigation Addendum, displays
monitoring well locations for wells installed through 1991. Additional wells were installed in
March of2002 as partial-implementation of the recommendations of the Supplemental
Evaluation of Monitored Natural Attenuation at the Potter's Pits Site, Sandy Creek, North
Carolina (EPA, 2000). The approximate locations for the new wells are shown on Figure 4.
Figure 3. Monitoring Well Locations
LEGEND
0 Shallow Monitor Well
,:_, Deep Monitor Well
MIi-2~ . ICU. U .... ICAM)M
MW-205 0
W-,06 IW-01 1:1 0 -
FiJJe-Year &Pieu,
Poller's Septif Tank Seroice Pits. Sand_)· Crrek, NC
0.1.···.·.·•·· L -~
(''::©
t:J 0 uw-w .. _,;.
..__,____
UW-101 ,;,
8 EPA-09(:J
1:,[PA-08 Pt,.-~, .
uw-201
-Welllde11dflN uPW-1 ts aru:ldmtJalwe!L IIISLlllled Ill 11191.
Wei.II ldendJled as EPA-## are momlllr wells. lmtalled In l.!114.
Welll ldeDWled uMW--1111# are11U1dor wells. Installed In 1990 ud 11191.
Wiill .ldandflad qTW-11# an TIDlflOrsrJ walls. lmtalled In 1991.
~ Ai'(•~.:. 'iCAI.( ~ JU I
Joi~ ,, ~ '· 100
-------~ j
8 ro . ____ · -:-:-~~---~,_o,-·~--'-'~"
11
lOCAUlHf Of SUAUOW AND O[(t•
UOCtilON WfUS Al II~ :5.HC
··--.MCPtlL-lHvi S1'4Jl()N AOQ[h()u;.. ·
. f Oll ll IC f'Of1£R5 ·
Sl,uc r.AHK·· SCRYICC. PUS SH[
.. S~t C,U~ • .-~J~. CAAOc,....., .
•
•
Figure 4. New Monitoring Well Locations
Excavation Areas
! -/ / ---
!
m POTTER'S 5tPJ1C SDMCC PITS SAHOY CREEK. iRUNSwtCK C0(.9ff\', MORIH CAROliU.
12
,.s ,t ~ c;
. '\\'-
Fivr-Year Rtvin,,
Poller's Septic Tank Service Pits, San4J· Crrek, NC
_ M\,i-102
-
+~rnNGSIWllh'
♦ EXI.STING DC.a" l,l[ll ,I...._._._
·V WCU
♦ PLNM:D DaP '-0..l
I Not installed i ~·
-
1111 i.ATOUT iu,
•
•
C. Progress Since the Last Five-Year Review:
•
Five. Year Rtview
PollerJ Septic Tank Sm,ia: !'its. Samfy Creek, NC
Since tliis is the first Five-Year Review Report, no other report is available and thus no
· progress is reportable.
V. FIVE-YEAR REVIEW PROCESS
The five-year review process for the Potter's Septic Tank Service Pits site included
telephone discussion/interviews with the EPA Remedial Project Manager (RPM), and the lead
State agency. Also included, were several visits to the Leland Public Library, the public
repository for the remedial action documents, and a visit to EPA Region IV offices in Atlanta,
Georgia to obtain copies of relevant documents for review. A list of pertinent materials from the
Leland Public Library, the EPA Region IV offices, and other sources is provided in Attachment
I.
The following persons were members of the five-year review team:
♦ Greg Mellema, Hazardous, Toxic, and Radioactive Waste Center of Expertise
(CENWO-HX-G), Omaha, NE
♦ Steve White, Hazardous, Toxic, and Radioactive Waste Center of Expertise (CENWO-
HX-G), Omaha, NE
♦ Phil Payonk, Wilmington District, Environmental Resources Section (CESA W-TS-PE)
♦ Stacy Samuelson, CESA W-TS-PE
VI. FIVE-YEAR REVIEW FINDINGS
A. Interviews
The following persons were interviewed regarding the activities and implementation of
the remedial actions at the Potter's Pits Site: . I
Ms. Beverly Hudson, Remedial Proiect Manager, EPA Region IV:
In several telephone conversations between Stacy Samuelson and Ms. Hudson, two issues
pertaining to the Potter's Pits Site were identified. The timing of sampling evJnts of the
groundwater monitoring wells was discussed as well as implementation of a sampling protocol
for the new wells installed in March of 2002. The second issue, implementation of Institutional
Controls, was addressed as well. Ms. Hudson indicated that the monitoring protocol was under
development and the Institutional Controls were in the coordination stage with the property
owner and the State of North Carolina. Additional discussion of these issues are provided.in
Sections VIII, Issues, and IX, Recommendations and Follow-up Actions.
Mr. Nile Testerman, Environmental Engineer, North Carolina Department o(Environment and
Natural Resources, Division of Waste Management, Superfund Federal Remediation Branch:
13
• •
Five-Year &view
PollerJ Septit' Tank Service Pits, Sa11r!J• Crrek, NC
Stacy Samuelson, Wilmington District, made initial contact with Mr. Testerman through
a telephone conversation. Mr. Testerman indicated that the State has some concerns about the
. Institutional Controls proposed in the AROD. The implementation of Institutional Controls for
· the site is a major goal for the State. Mr. Testerman feels that coordination between EPA and the
State Attorney General's office is a necessity.
The Natural Attenuation remedy allows for additional groundwater monitoring wells.
These additional wells were installed as part of the remedial action for the site. An initial
quarterly monitoring frequency was conducted for the site. This monitoring frequency will be
changed to either once or twice per year after the initial year of data have been obtained.
B. Site Inspection
A site inspection of the Potter's Pits Site was conducted on April 12, 2002. Attending the
site visit were:
♦ Nile Testerman, Environmental Engineer, North Carolina Department of Environment
and Natural Resources, Division of Waste Management, SF Federal Remediation• I . Branch. !
♦ Phil Payonk, U.S. Army Corps of Engineers, Wilmington District.
♦ Stacy Samuelson, U.S. Army Corps of Engineers, Wilmington District.
Local community members who had expressed interest in the site at previous public
meetings were informed of the site visit by Ms. Hudson, RPM of the site. Ms1 Hudson contacted
the following persons about the site visit:
♦ Mr. Ronnie Gore
♦ Ms. Grainger
♦ Ms. Etta Minnis
♦ Mr. Bob Newlow
♦ Mr. Samuel Caines
♦ Mr. Patrick McDonagh
♦ M/M. James Britt
♦ M/M. Glenn Richardson
♦ Mrs. Gaye Mitchell
♦ M/M. Earl Gurkin
The following persons attended the site visit to ask questions and express concerns:
♦ Mr. Ronnie Gore
♦ Mrs. Gaye Mitchell
♦ Mr. Bob Newlow
For documentation of the site visit, photos of the main excavation area were taken and are
attached as Attachment 2.
14
• • Five-Year Review
Pol/er's Septir Tank Servi,-e PitI, Samfy Creek, NC
The site area has not been re-developed since the source remedial action was completed in
1996. The area is currently vegetated with grasses and has been mowed. Mr. ~esterman gave a
'. brief historical overview of the activities and locations of facilities during the source remedial
action. He stated that the main excavation area was the area shown in the photos (Attachment 2),
and the lots across Grainger Drive were where the L TTD equipment had been staged.
The only items of immediate note at the site were two monitoring welts toward the center
of the site that are not flush 'with the· ground surface, and staged barrels of waste from the recent
monitoring well installation and sampling effort. There were 38 55-gallon barrels and several
plastic bags of Investigative Derived Waste (IDW). The ID_W will be removed prior to
completion of fieldwork. Upon further investigation of the site area, it was noted that several of
the older monitoring wells located on the northern periphery of the site were not locked and
therefore prone to tampering.
·while on site, Mr. Gore, the owner of the lot comprising the southern portion of the site
stopped by to express some concerns. Mr. Gore contends that he is not able to replace a septic
system that was damaged during the source remediation activities. His claim is that at the time
of the damage, he was told that the septic system could be replaced without a new permit, but
now he cannot get a contractor to install a new system without a permit. Mr. Gore would also
like to receive the results of the recent groundwater sampling when they become available, This
information was passed on to Ms. Hudson during Mr. Samuelson's visit to EPA in Atlanta.
Mrs, Mitchell had several questions pertaining to future use of the site and some
questions about dying vegetation along the Chinnis Branch. On further discussion, Mrs, Mitchell
noted that there had been quite a bit of vegetative mortality resulting from storm damage caused
by· recent hurricane events since 1996.
Mr, Newlow, the property owner on the east side of Chinnis Branch adjacent to the site
discussed his concerns about the potential for groundwater contamination occurring under his
property. Additionally, Mr. Newlow is concerned that he could be displaced fr~m his property.
as a result of activities related to remedial actions at the site.
After walking the site area and noting the locations of the newly installed monitoring
wells, the site visit was concluded. The removal of the barrels of IDW left on the site was
discussed with Ms. Hudson by Mr. Samuelson during a visit to EPA in Atlanta. The work plan
submitted by Black & Veatch calls for removal of all materials by November 2002, but it seems
that earlier removal would be possible.
A final walkthrough inspection of the site was conducted the week of July 22, 2002 by
Ms. Hudson, RPM, Community members who had concerns at the April 12, 2002 site visit were
contacted during the inspection,
15
•
C. ARAR Review
• Five-Yrar Review
Poller! Septic Tank Servife Pits, Santfy Cruk, NC
, In performing the five-year review for compliance with applicable or relevant and
· appropriate requirements (ARARs), only those ARARs addressing risk posed to human health or
the environment (i.e., addressing the protectiveness of the remedy) were reviewed. This is in
keeping with current EPA guidance·on five-year reviews.
Federal ARARs
♦ Federal Groundwate'r Classification -55 Federal Register (FR) Part 8733.
♦ Safe Drinking Water Act of I 986, as amended (40 USC §§ 300) -40 CFR Part 141.
♦ Solid Waste Disposal Act (40 USC § 690 I -6987) -40 CFR Part 261.
♦ EPA Regulations on Sole-Source Aquifers -40 CFR 149.
State ARA Rs
♦ Identification and Listing of Hazardous Waste - I SA NCAC I 3A.0006.
♦ North Carolina Drinking Water Act -General Statutes, Chapter 130A, Article I 0.
♦ North Carolina Water Quality Standards - I SA NCAC 2B.
♦ North Carolina Groundwater Quality Standards - I SA NCAC 2L.0 I 00, 2L.0200,
2L.0300.
The site appears to be in compliance with the ARARs identified in the ROD. There were
no changes in the reviewed ·statutes and standards that would require changes in the remedy or
management of the site.
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics
No changes in the site conditions that affect exposure pathways were identified as part of
the five-year review. There are no current or known changes planned in the land use and it is
likely to remain rural residential immediately adjacent to the site. No new contaminants,
sources, or routes of exposure were identified as part of this five-year review. fhere is no
indication that hydrologic/hydrogeologic conditions are not adequately characterized. The rate
of decrease of contaminant levels in groundwater is consistent with expectations, and the
groundwater plume appears to be contained. Toxicity and other factors for contaminants of
concern have not changed.
E. Data Review
As a result of issues identified in the document review, interviews and site inspection, the
principal data reviewed related to soil and groundwater· contaminant levels of the site. The main
resource for review of data was the Evaluation of Monitored Natural Attenuation at the Potter's
Pits Site, Sandy Creek, North Carolina report (Evaluation Report) and associated appendices
(June 2000).
16
Soil Data
• t'lve-Year &view
PollerI Septic Tank Service PitJ, Sandy Crrek, NC
Soil contamination data have not been collected since the completion of the Remedial
· Action. Table 5 summarizes pre-excavation and post-excavation soil contaminant concentrations
from Appendix 6 of the Evaluation Report.
Table 5. Pre-and Post-Excavation Soil Concentration Data
Contaminant of Pre-Remedial Action Post-Remedial Action
Concern (mean) (mean)
Benzene UQ/Kg 8560 260
Toluene UE!/Kg 21377 1176
Ethvlbenzene UQ/Kg 64228 516
Xylenes UE!/Kg 157390 3801
Naphthalene ui,/Kg 18248 3364
Chromium mg/Kg 6 NS*
Lead mg/Kg 29 NS
*NS = Not Sampled I
Data from samples with at least one contaminant above non-detect do not include non-
detects in the calculations.
Source: Evaluation Report (EPA, 2000), Appendix 6
Groundwater Data
Groundwater sampling data was reviewed for sampling events occurring from May 1984
to the present. Table 6 lists sampling dates, wells sampled and source of the data. Gaps in the
data are due to wells not being installed at the time of sampling, or just not being sampled. The
only two wells sampled consistently over the history of the data reviewed were EPA-02 and
EPA-04. Figures 5 and 6 show the maximum detected values for benzene and ethylbenzene.
Those compounds were the most consistently detected over the sampling period.
17
Table 6. Sampling Efforts by Well Number
Sampini Dair
-4• ~· __ ,.
Jwt-91 Au•-93 Jpn-96 Jul-97 11--98 i-Drt-98
roata--' (EPA June 2000) (EPA June 2'000) (EPA fone 2000) (EPA fone 2ot)O) (EPA June 2000) (EPA Junc 2000) (EPA June 2000) EPA Au~ t EPA
~' 19'J8 ,..,,,.,
'"" ?~rt:..
EPA-02 X X X X X X X X X
EPA-03 X X X X X X X
El'A-0< X X X X X X X X X
EPA-05 X X X X X X X
El'A-06 X X X X X X X
EPA-07 X X X X X X X X X
El'A-01 X X X X X X X X X
El'A-00 X X X X X X X
MW-101 X X X X X X X
MW-102 X X X X X
MW-104 X X X X X X X
MW-105 X X X X X
MW-106 X X X X X X X
MW-1060
MW-110 X X X X X X X
MW-111 X X X X X X X
MW-201 X X X X X X
MW-202 X X X X X X
M\\'-203 X X X X X X
MW-204 X X X X
MW-205 X X X X
MW-206 X X X X
MW-207 X X X X
MW-210 X X X X
MW-211 X X X X
MW-301
MW-102
MW-J0J
MW-304
MW-305
MW-306
MW-.l07
MW--101
MW-CO2
MW-COl
MW...co4
MW-405
MW-""
MW-C07
MW..,.10
MW..,.11
MW_.12
18
Five-Year Review
Polterf Septir Tank Semite PitI, Sa111J• Creek, 1\7C
19-Jult-OO 29-0tl-01 lb-!\b~-02
EPA Ju~ '" U'l.\t.,-,ooo ""'°""" 1m1
21)01
X X
X X
X X
X X X
X X
X X X
X X X
X X X
X X
X X
X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X
X
X
X
X
X
X
X
X
X
•
•
• • Fivt-Ytar &view
Po!ler's Srptic Tank Service Pils, Sandy Cr?ek, NC
Figure 5. Maximum Benzene and Ethylbenzene Concentrations in all Potter's Pits
Groundwater Monitoring Wells 1984 -1993
Mulmum Groundwater ConcentraUon1 Pre-Remedlal AcUon
'2000
10000
eooo
1 6000
2000
(UWoUo)
~
i.
Sa~li11g OatH
Note: 6 ftg/L August 93 is benzene, cthylbcnzene was not sampled August 93.
Figure 6. Maximum Benzene and Ethylbenzene Concentrations in all Potter's Pits
Groundwater Monitoring Wells 1996 -2002
J l
Maximum Groundwater Concentrations Poat-Remedial Action
,oo
00
"
70
60
"'
"
3-0
"
20
(l'"•ll•l "
~ '
. . ~ • ~ , i £ C ' u :! 0
Sa"1>1ingDatn 1011,;n,..,.■11~,.._,,_I
Note: May 98 -ethylbenzene was sampled but not detected.
not analyzed for.
July 97 ethylbenzene was
I
19
• • f:ive-)'ear Rtview
Potter's Septic Tank Service Pili, Sanrjy Creek, NC
Concentrations illustrated are maximum concentrations from all wells sampled on the
specified sample date. Number of wells sampled is in parentheses. Note that the contaminant
concentration scale on Figure 5 (Pre-Remedial Action) is ten times greater than that of Figure 6
.' (Post-Remedial Action), demonstrating an overall reduction of contaminant levels at the site.
VII. ASSESSMENT
To assess the effectiveness of the remedy at the Potter's Septic Tank Service site, three
basic questions are answered and discussed below:
Question A: Is the remedy functioning as intended by the decision documents?
For the Potter's Septic Tank Service Pits Site, the remedy for soil (source) contamination
was completed in 1996, with the conclusion of L TTD soil treatment. Based on a final inspection
of the site by EPA and the State of North Carolina Division of Superfund in 1999, the soil
contaminant level goals established in the ROD and RD have been met and no further soil
remediation is required.
The 1996 soil remediation clearly had the effect of reducing groundwater contaminant
concentrations. The groundwater contamination trends attributable to the MN,._! remedy cannot
be determined. The trends of contaminant concentrations in groundwater are difficult to discern
because of frequent changes in the sampling program.
Implementation of the Institutional Controls recommended by the AROD has not.
occurred to date. Coordination between the EPA, State of North Carolina, and the landowner is
underway. This matter is discussed further in the Issues and Recommendations section of this
review.
Question B: Are the assumptions used at the time of the remedy selection still valid?
The assumptions used for the remedy selection remain valid. The selection of monitored
natural attenuation as the remedy is still valid as there have not been any changes to the
assumptions made originally. Based on the review, all appropriate measures and procedures
were utilized at the time of the remedial action and continue to be in effect.
Question C: Has any information come to light that could call into question the protectiveness
of the remedy?
Based on validated inforrnation provided in the documentation that was reviewed, there is
no information to date that significantly questions the protectiveness of the remedy. Data
collected since the conclusion of the source remedial action support the selection of monitored
natural attenuation (MNA) as the preferred method for groundwater remediation in the AROD.
The trends of contaminant concentrations in groundwater are difficult to discern because of
frequent changes in the sampling program. Remedy implementation data t~ date provide no
validated early indication of potential remedy failure.
20
•
VIII. ISSUES
• Five-Ytar Rrview
1 Polter's Septic Tank SerPia Pilf, Samfy C,uk, NC
There are two problems or issues that have been identified during this review. Each is
.' further discussed in the recommendations section of this report.
I. Institutional controls for the site as proposed in the documents of record have not been
implemented.
2. Monitoring wells need to be checked to ensure all are properly secured to prevent
tampering.
IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS
The recommendations and follow-up actions associated with the issues found in this
review are described below and are summarized in Table 7.
Implementation of the Institutional Controls as proposed in the Record of Decision and
Amended Record of Decision should be pursued. The controls as proposed consist of restrictive
covenants and deed recordation for the site lots as related to groundwater. The ~roposed controls
consist of restriction of ground disturbing activities to no deeper than 25 feet below the ground
surface, and prohibition of installation of potable water wells in the site area. It is recommended
that EPA continue to coordinate the implementation of the proposed controls with the property
owners (Mr. Gurkin and Mr. Gore) and the North Carolina Attorney General's office. Once
implemented, the lnstitution_al Controls should be reviewed for applicability dLring the next five-
year review, as the Sandy Creek area may be developing a community-wide water supply system
in the near future.
The installed monitoring wells need to be properly secured to insure integrity. Proper
installation of locks will prevent tampering and potential destruction of monitoring wells around
the site.
Institutional
controls for the
site as proposed
in the
documents of
record have not
been
imo lemented.
Monitoring
wells need to be
properly
secured.
Table 7. Recommendations and Follow-up Actions
Implement Institutional
Controls and review
implementation in next
five-year review.
Properly secure all
installed monitoring
wells to prevent
tamoerine:.
EPA and State EPA and State
EPA EPA
21
Before next
five-year
review as
required
Before next
five-year as
required
N
N
•
X. PROTECTIVENESS STATEMENTS
• Five-Year &view
Potter's Septic Tank Service Pili, Santfy Creek, NC
The remedy at the Potter's SepticTank Service Pits Site currently protects human health
and the environment because the main source of contamination has been remediated through the
L TTD treatment of the contaminated soils. However, in order for the groundwater remedy to be
effective in the long-term, the following actions need to be taken to ensure long-term
protectiveness: Implementation of the Institutional Controls delineated in the AROD.
XI. NEXT REVIEW
This is a site that requires five-year statutory reviews. EPA will conduct the next review
within five years of the completion of this first five-year review report. The dompletion of this
review as shown on the signature cover to this report is the trigger for the next five-year review.
22
• • Five-Year &vitw
Pol!er'.r Sep!it' Tank Serllia Pits, Sanrf_y Crttk, NC
List of Documents Reviewed
Potter's Septic Tank Service Pits Five-Year Review
Ebasco Services, Inc. September 1990. Final Remedial Investigation, Potter's Pits Septic Tank
Pits Site, Sandy Creek, North Carolina.
Roy F. Weston, Inc. April 1992. Revision I; Remedial Investigation Addendum Report, Potter's
Pits Site, Sandy Creek, North Carolina; Work Assignment No. 07-4LC4.
Roy F. Weston, Inc. April 1992. Revision I; Remedial Investigation Addendum Report,
Appendix A and Appendix B, Potter's Pits Site, Sandy Creek, North Carolina; Work Assignment
No. 07-4LC4.
Roy F. Weston, Inc. April 1992. Feasibility Study, Potter's Pits Septic Tank Pits Site, Sandy
Creek, North Carolina, Revision I.
April 16, 1992. Memorandum: Additional Information for the Feasibility Report, Potter's
Septic Tank Service Pits, Sandy Creek, North Carolina; Attachment I: Memorandum on
development of soil cleanup levels; Attachment 2: Additional Soil Alternative: Low
Temperature Thermal Desorption; Attachment 3: Information on Thermal Desorption.
May 12, 1992. Transcript ofEPA.Superfund Proposed Plan Meeting, Sandy Creek, North
Carolina.
U.S. Environmental Protection Agency, Region IV. August 5, 1992. Record of Decision;
Summary of Remedial Alternative Selection; Potter's Septic Tank Service Pits, Sandy Creek,
Brunswick County, North Carolina.
U.S. Environmental Protection Agency, Region IV. February 1993. Superfund Remedial Action
Amended Community Relations Plan for Potter's Septic Tank Service Pits, Sandy Creek,
Brunswick County, North Carolina.
I U.S. Environmental Protection Agency, Region IV. January, 1995. Remedial Design Fact Sheet
Phase I -Soil Remediation; Potters Septic Tank Service Pits Site, Sandy Creek, North Carolina.
U.S. Environmental Protection Agency, Region IV. February 9, 1996. Superfund Program
Explanation of ~ignificant Difference Potter's Septic Tank Service Pits Site, S
1
andy Creek,
Brunswick County, North Carolina.
U.S. Environmental Protection Agency, Region IV. February 28, 1996. Potter's Septic Tank
Service Pits [ESD] NPL Site Administrative Record, Index and Volume I.
24
• • Five-)'ear &view
Poller! Septic Tank Service PitJ, Santfy Creek, NC
U.S. Environmental Protection Agency, Science and Ecosystems Support Division. August 5,
1998. Potters Pits, Sandy Creek, North Carolina, Field Investigation Report. SESD Project No.
98-429.
U.S. Environmental Protection Agency, Science and Ecosystems Support Division. February 18,
1999. Potters Pits, Sandy Creek, North Carolina, Field Investigation Report. SESD Project No.
99-0068. /
U.S. Environmental Protection Agency, Science and Ecosystems Support Division. July 28,
2000. Report of Findings for the Installation and Sampling of Monitoring Wells at the Potter's
Pits Site.
U.S. Environmental Protection Agency, Region 4. June 2000. Evaluation of Monitored Natural
Attenuation at the Potter's Pits Site, Sandy Creek, No.rth Carolina.
U.S. Environmental Protecti_on Agency, Region 4. July 30, 2000. Statement of Work for
Feasibility Study Amendment, Potter's Pits, Sandy Creek, Brunswick County, North Carolina.
U.S. Environmental Protection Agency, Office of Technical Services, Waste Management
Division. September 5, 2000. Supplemental Evaluation of Monitored Natural Attenuation at the
Potter's Pits Site, Sandy Creek, North Carolina. William N. O'Steen, principal preparer.
Black & Veatch Special Projects Corporation. August 11, 2000. Draft Work Plan, Feasibility
Study Amendment, Potter's Pits, Leland, Brunswick County, North Carolina.
U.S. Environmental Protection Agency, Science and Ecosystems Support Division. December
19, 200 I. Potter's Septic Tank Services Pits Site, Sandy Creek, North Carolina, Field
Investigation Report. SESD Project No. 02-0038.
Black & Veatch Special Projects Corporation. February I, 2002. Task Health and Safety Plan,
Potters Pits Site, Monitoring Well Installation Oversight, Groundwater Sampling, and IDW
Disposal Oversight.
Black & Veatch Special Projects Corporation. February I, 2002. Site Health and Safety
Program (Site HASP), Potter's Pits Site.
•
ATTACHMENT 2
26
• Five-Year Rtview
Potter'.r Septic Tank Service Pits, Santfy Cruk, NC
•
Northwest Comer looking Southeast. :"Jortheast Comer looking South.
•
Southwest comer looking North. Southwest comer looking East.
•
Southv,:est corner looking North, South of Joi:-Baldwin Dr. looking Southeast.
•
Monitoring well. Monitoring well.
•
•
Older monitor'ing well. Old monitoring well -note missing lock.
•
Northeast comer looking South. Northeast comer looking Southwest.
•
Detail of existing well.
•
Southeast comer looking Northwest. Mr. Gore·s gates on south side of Joe Baldv,:in Dr.
•
. .)"!:;'l,_":·:·~~.
It:':::~~:: •
New well and old well on south side of Joe Baldwin Dr. S(!utheast corner of Mr. Gore ·s lot looking west.
•
Southeast comer of Mr. Gore's lot looking northwest.
NORTH CAROLINA
DEPARTMENT OF ENVJRO.NT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
MICHAEL F. EASLEY, GOVERNOR
WILLIAM G. Ross, JR., SECRETARY
DEXTER R. MA 'ITHEWS, DIRECTOR
• 8-?'A --_u;,1..~ n ,,;, ___ _
NCDEMR
20 June 2002 FILE COPY
Ms. Beverly Hudson
Superfund Branch. Waste Management Division
US EPA Region JV
6 I Forsyth Street. SW
Atlanta, Georgia 30303
SUBJECT: Comments on draft Five-Year Review Report (June 2002)
Potter's Septic Tank Service Pits
Sandy Creek, Brunswick County
Dear Ms. Hudson,
The State of North Carolina has reviewed the draft Five-Year Review Report dated June
2002 and received by the Division on 12 June 2002 for the Potter's Septic Tank Service Pits
Superfund site. The following comments are offered:
1. List of Acronyms: Please add AROD, SESD, MNA, CENWO-HX-G, CESAW-TS-PE,
IDW, and LTTD. Please delete the acronyms not used in the report.
2. Table 4: Table 4 lists the revised standards for groundwater as listed in the amended
Record of Decision (AROD). Please be aware that the original cleanup goals for toluene,
xylenes, chromium and lead are also applicable.
3. Sei:tio_n E, page 16 and Table 5: Please note that the data are from samples that had at
least one contaminant above non-detect and does not include non-detects in the
calculations.
If you have any questions or comments, please call me at 919 733-2801, extension 350.
Sincerely,
Nile P. Testerman, PE
Federal Remediation Branch
Superfund Section
1646 MAIL SER\1CE CE!'.TER, RALEIGH, NORTII CAROLINA 27699-1646
401 OBERLl1'" ROAD, SUITE 150, RALEIGH, NC 27605
Pil01''E: 919-733-4996 \ FAX: [phone]
As EQUAL OPPORTii1'1TI'/AFFUU1,tATI\'EAcno1" EMPLOYER •50% RECYCLED/10% POST-CONSUMER PAPER