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• • Preliminary Close Out Report Reasor Chemical Company Site
2L
ATV
BHHRA
CERCLA
DPLUR
EPA
ERA
HQ
!Cs
IDW
MCL
MW
NC
NCDENR
NCP
NPL
O&F
O&M
OSWER
PAHs
PRPs
PSVP
QA/QC
RA
RD
RI/FS
ROD
SMCL
SVOCs
voes
XRF
List of Acronyms
North Carolina Administrative Code, Subchapter 2L, Groundwater
Classification and Standards
Alternate Toxicity Value
Baseline Human Health Risk Assessment
Comprehensive Environmental Response, Compensation, and Liability Act of
1980
Declaration of Perpetual Land Use Restrictions
United States Environmental Protection Agency
Ecological Risk Assessment
Hazard Quotient
Institutional Controls
Investigation Derived Waste
Maximum Contaminant Level
Monitoring Well
North Carolina
North Carolina Department of Environment and Natural Resources
National Contingency Plan
National Priorities List
Operational and Functional
Operation and Maintenance
Office of Solid Waste and Emergency Response
polycylic aromatic hydrocarbons
Potentially Responsible Parties
Performance Standards Verification Plan
Quality Assurance/ Quality Control
Remedial Action
Remedial Design
Remedial Investigation/ Feasibility Study
Record of Decision
Secondary Maximum Contaminant Level
semi-volatile organic compounds
volatile organic compounds
X-ray Fluorescence Spectrometer
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• • Preliminary Close Out Report Reasor Chemical Company Site
1.0 INTRODUCTION
This Preliminary Close Out Report documents that the Potentially Responsible Parties (PRPs) at
the Reasor Chemical Company Superfund Site (the Site) completed construction activities in
accordance with Close Out Procedures for National Priorities List Sites (OSWER Directive
9320.2-09A-P). The United States Environmental Protection Agency (EPA) and the North
Carolina Department of Environment and Natural Resources (NC DENR) conducted a pre-
. final/final inspection on July 26, 2007, and determined that the PRPs' contractor had constructed
the remedy in accordance with the Remedial Action Work Plan which was developed in
accordance with the final Record of Decision (ROD), as amended, for the Site. No further
remedial action construction activities are anticipated at the Site.
2.0 SUMMARY OF SITE CONDITIONS
2.1 Background
The Site is located at 5100 North College Road (Hwy 132) in Castle Hayne, New Hanover
County, North Carolina. Castle Hayne is approximately 13 miles north of
Wilmington, NC. The city had a population of I, 116 in the year 2000, according to census data.
From the road the Site appears to be a large wooded vacant lot across from the Apex Asphalt
Company near the intersection of Hwy 132 and Kings Castle Road. It is bordered on the
southeast by Prince George Creek. The Site's coordinates are latitude 34° 20' 36.5" N and
longitude 77° 53' 31" W. The Site is currently zoned industrial. Both industrial and residential
properties neighbor the Site property. The PRPs at the site include Martin Marietta Materials,
Inc., Jane C. Sullivan and Hilda C. Dill. The Site and surrounding parcel owned by two of the
PRPs is planned to be rezoned from heavy industrial to a mixture of commercial and residential.
Drinking water in the area is obtained from private wells and community wells. The closest
community well is located in a mobile home park 1,500 to 2,500 feet southwest of the site
(Shady Haven MHP). Another community well is located 3,000 feet southeast of the site in a
housing subdivision (Prince George Estates). The closest domestic well is located 1,200 feet
from the site. These three wells tap into the Peedee and Castle Hayne aquifers and range in
depth from 148 to 150 feet below ground surface.
The water table at the site is typically found in unconsolidated overburden materials. The
surficial aquifer ranges in thickness from 17 feet thick on the southwest and northeast portion of
the site to 29 feet thick on the southeast portion of the site. The depth to water in the surficial
aquifer ranges from approximately 3 to 12 feet. Groundwater flow direction follows site
topography, flowing from the higher area contours at the northwestern edge of the site southeast
toward the channel of Prince George Creek. The only wells at or near the site which indicated
contaminants of concern above cleanup goals during Remedial Investigation/Feasibility Study
(RI/FS) or Remedial Design (RD) activities are wells MW-7S and MW-7D (which are located
near the center of the site property). The groundwater depths for these two wells range from 4 to
11 feet below the land surface.
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• • Preliminary Close Out Report Reasor Chemical Company Site
The Site, comprised of approximately 25 acres, is an abandoned stump rendering facility, which
operated from 1959 to 1972. The Reasor Chemical Company produced turpentine, pine resin,
pitch, tall oil, pine oil, camphor, pine tar, and charcoal from pine tree stumps. It is believed that
the facility used various solvents to extract raw product from chipped stumps, distilling the
extract into separate product fractions. A fire and possible explosion occurred on the property on
April 7, 1972, which damaged and destroyed the remaining buildings and material on the site
property. The property is currently vacant, is overgrown with brush and secondary growth
forest, and has unpaved roads running throughout the site. There are a few site features which
are still distinguishable, which include: three tank cradle areas, a boiler house, concrete slabs
from the former rosin warehouse, laboratory, garage, still, process line, transformer area, train
scale, and several other unidentified former buildings. Five ponds used in the manufacturing
process, a scrap copper area, two railroad sidings, a surface drum disposal area, a sluice area, and
several drainage ditches were also present at the site. Appendix A includes a Site Figure.
The EPA proposed the Site to the National Priorities List (NPL) on September 13, 2001 through
publication in the Federal Register (Volume 66, Number 178). The Site was finalized on the
NPL through publication in the Federal Register on September 5, 2002 (Volume 67, Number
-172).
2.2 Removal Actions
In 1991, EPA conducted a removal assessment at the Site and determined that a removal action
was not warranted.
2.3 Extent of Contamination
The Remedial Investigation/Feasibility Study was completed by contractors for EPA in 2002.
EPA completed the Ecological Risk Assessment that same year. The Remedial Design was
completed by contractors for EPA in 2004. Information from those three events, as well as the
Human Health Risk Assessment, was evaluated to determine the extent of contamination above
cleanup goals specified in Table 47 of the 2007 ROD Amendment (see Table I on page 9). The
following bullets summarize.the extent of contamination, as presented in the 2007 ROD
Amendment. A Site figure can be found in Appendix A.
• Surface soils are contaminated with polycyclic aromatic hydrocarbons (PAHs) and
metals above cleanup goals specified in the 2007 ROD Amendment (see Table I) in the
following areas: Scrap copper, pipe shop, and drum disposal. Contamination above
cleanup goals extends to a depth of approximately one foot. The estimated volume of
contaminated surface soil is 345 cubic yards (yd3).
• Sediments are contaminated with volatile organic compounds (VOCs), semi-volatile
organic compounds (SVOCs), PAHs and metals at concentrations that exceed cleanup
goals specified in the 2007 ROD Amendment (see Table I). The volume of
contaminated sediment is approximately 1,075 yd3 from four specific areas: Pond I,
Pond 2, Pond 3 and Pond 4.
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• • Preliminary Close Out Report Reasor Chemical Company Site
• Surface water is contaminated with metals at concentrations that exceed cleanup goals
specified in the 2007 ROD Amendment (see Table I). The volume of contaminated
surface water is approximately 344,000 gallons and is currently located in Ponds 1 and 2.
(Note: Ponds 3 and 4 were dry during several visits to the property.)
• Groundwater is contaminated with aluminum, beryllium, chromium and nickel at
concentrations that exceed cleanup goals specified in the 2007 ROD Amendment (see
Table I) in two monitoring wells located towards the middle of the Site property, MW-7S
and MW-7D. The groundwater depths for these two wells range from 4 to 11 feet below
the land surface.
2.3 Selected Remedy
The remedy for the Site was selected in a ROD on September 26, 2002, and addresses the Site as
one Operable Unit through remedies that cleanup contaminated soil, sediments, surface water .
and ground water that was present on the site property. During the Remedial Design and while
negotiating with PRPs, additional information was gained which led EPA to amend the ROD on
June I, 2007. The amended remedy included the following response actions:
0 Excavation and off-site disposal of the approximate 1,420 cubic yards (yd3) of
contaminated soil and sediment above cleanup goals specified in the 2007 ROD
Amendment (see Table I) from the scrap copper area, the pipe shop, the drum
disposal area, Pond I, Pond 2, Pond 3 and Pond 4;
0 On-site treatment and disposal of approximate 344,000 gallons of contaminated
surface water from Ponds I, 2, 3 and 4;
0 Backfill the excavated soil areas and vegetate with native plant species; return the
former ponds to wetland habitats;
0 Backfill the drum disposal area with an alkaline substance to raise the pH of
shallow groundwater;
0 Perform annual monitoring of groundwater to determine if contaminants of
concern continue to be elevated above cleanup goals specified in the 2007 ROD
Amendment (see Table I);
0 Attach a Declaration of Perpetual Land Use Restrictions (DPLUR) to the property
title that prohibits the use of shallow groundwater for any purpose.
As described in the 2007 Amended ROD, the remedial action objectives associated with the
above noted site response actions are as follows:
Sediment:
• prevent further migration of contaminants from sediment to groundwater and surface
water above levels exceeding groundwater and surface water cleanup goals (Table I)
• eliminate exposure of ecological receptors to contaminated sediment
• achieve ecological risk based sediment cleanup goals (Table 1) for: methyl ethyl ketone,
toluene, (3-and/or 4-)methylphenol, total PAHs, and copper •
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• • Preliminary Close Out Report Reasor Chemical Company Site
Surface water:
• prevent further migration of contaminants above cleanup goals (Table 1) from Ponds 1, 2,
3 and 4, to soil, groundwater and down-gradient surface water bodies
• eliminate exposure to contaminated surface water above levels exceeding cleanup goals
by aquatic receptors
• achieve the North Carolina Surface Water Quality Standards (NCAC Title 15A, Chapter
2, Subchapter 2B.0100 and 2B.0200) in Ponds 1, 2, 3 and 4 for: copper, lead, iron and
zmc
Soil:
• prevent further migration of contaminants from soil to groundwater and surface water
above levels exceeding groundwater and surface water cleanup goals (Table 1)
• eliminate unacceptable risk to human health and the environment
• achieve the human health and ecological risk based cleanup goals (Table 1) for:
benzo(a)pyrene, benzo(b &/or k)fluoranthene, dibenzo(a,h)anthracene, total PAHs,
antimony, copper and lead.
Groundwater:
• prevent human consumption of contaminated groundwater until risk-based standards for
aluminum, and Safe Drinking Water Act Maximum Contaminant Levels (MCLs) for
beryllium, chromium and nickel, are attained
2.4 Remedy Implementation
Remedial action construction activities began at the Site on June 4, 2007. The work was
performed by the PRPs' contractor, Apex Companies, LLC, (Apex) under a Consent Decree with
three of the PRPs (Martin Marietta Materials, Jane C. Sullivan and Hilda C. Dill) which was
entered by the United States District Court for the Eastern District of North Carolina on
December 8, 2006. The Remedial Action Work Plan, Revision 2, was conditionally approved by
EPA on June 8, 2007.
2.4.1 Surface Water
Approximately 122,200 gallons of contaminated surface water above cleanup goals specified in
the 2007 ROD Amendment (see Table 1) from Pond 1 and Pond 2, as well as water from staged
drums of prior Investigation Derived Waste (IDW), were treated and land applied via spray
heads in the vicinity of the boiler house at the Site. Pond 3 and Pond 4 did not contain water at
the time of the remedial action, which was consistent with observations during prior Site
investigations . .It was noticed during sediment excavation that Ponds 3 and 4 had breaches in at
least one wall, which would ·explain the lack of water retention. The difference in the volume
estimated in the ROD Amendment is due primarily to seasonal fluctuations. The surface water
treatment process consisted of pumping water from the ponds through filter bags, followed by an
ion exchange resin for metals removal and then activated carbon for organic compounds
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• • Preliminary Close Out Report Reasor Chemical Company Site
removal. 1 Samples were collected prior to on-site disposal to confirm the treatment system was
successful at removing the contaminants from the water. According to Apex, the sample results
from the first batch of treated water indicated that the effluent was below the cleanup goals
specified in the 2007 ROD Amendment (see Table I). However, subsequent batches exceeded at
least one surface water cleanup goal but were discharged prior to receipt of analytical results. In
late August 2007, Apex returned to the Site and collected two soil samples in the area of treated
water discharge. The analytical results for these samples were below soil cleanup goals specified
in the ROD Amendment. These sample results are summarized in Table 3 in Section 3.2.
In the 2007 Amended ROD, EPA noted that to the maximum extent practicable, the treated
surface water from the ponds will be returned to the cleaned ponds to facilitate wetland
restoration and to address at least one community member's concern. However, due to the lag
time in receiving analytical data for sediment confirmation samples, this was not feasible. This
element of the amended ROD was based on a public comment that flooding of Prince George
Creek affects their property. Due to the extremely dry weather conditions and diligence by the
contractor, the water soaked into the land and did not result in any discharge to Prince George
Creek.
After completion of processing the surface water, the treatment system holding tank was
decontaminated. The 2,365 gallons of rinseate was pumped into a vacuum truck and disposed of
off-site by A&D Environmental.
2.4.2 Soil, Sediment and Drum Removal
Approximately 1,663.54 tons of excavated contaminated soil, sediment, and decaying drums
from the following areas were disposed of in the New Hanover County Landfill: Pond I, Pond
2, Pond 3, and the Drum Disposal Area. Due to elevated concentrations of some contaminants of
concern, New Hanover County Landfill would not accept all waste streams. Therefore, 326.27
tons of excavated soils and sediments from Pond 4, the Scrap Copper Area and the Pipe Shop
Area were transported to and disposed of in the Sampson County Landfill. The total volume of
soil, sediment and debris disposed ofin the two landfills was 1989.81 tons, which is only four
percent more than the Amended ROD estimated amount of 1915 tons. In addition, 39 metal
drums which contained IDW were disposed of at the New Hanover County Landfill. IDW purge
water from those drums was disposed of via the on-site water filtration system.
2.4.3 Restoration
After excavation was completed, samples were collected from the bottoms and sidewalls of
· excavation pits and analyzed by an independent laboratory to ensure cleanup goals specified in
the 2007 ROD Amendment were met. 2 Once analytical results were received, the excavated
areas were restored in the following manner. The Pi~e Shop area was backfilled with soils from
the property, covered with a natural geotextile fabric , and was then seeded with a native grass
(rye grass). The Scrap Copper area was backfilled with soils from the property, covered with
1 A photo of the surface water treatment system can be found in Appendix C.
2 Photo of sample co11ection in Pond I can be found in Appendix C.
3 Photo of roll of geotextile fabric can be found in Appendix C.
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• • Preliminary Close Out Report Reasor Chemical Company Site
mulch, and was then seeded with a native grass (rye grass). Approximately 2,520 pounds of
commercially available pelle6zed lawn lime4 was placed in the Drum Disposal Area over an area
of approximately 150 feet Jong by 50 feet wide and a thickness of approximately 1/16-inch. The
lime was then covered with soils obtained from nearby areas on the property. A geotextile fabric
was placed over the sloping sidewalls and rye grass seed was applied. The geotextile fabric used
at this Site consisted of a natural material woven into a mat surface which is porous to light and
rain, promotes seed germination and is bio-and photo-degradable.
The sidewalls of the ponds were sloped at a I :8 ratio using adjacent soils. Soils from the
property were added to the base of each·pond to cover the pre-existing clay liner and promote
regeneration of vegetative growth. The sidewalls were covered with a geotextile fabric and rye
grass seed was applied on the walls to prevent erosion. Due to the extent of excavation required
at Ponds I and 2, there was not enough remaining soil between them to slope the walls and keep
them as two distinct ponds. Therefore, EPA and NC DENR concurred with the PRPs' proposal
to remove the remaining soil between them to create one larger pond. It is anticipated that these
areas will naturally revegetate since they are surrounded by forest lands. Monitoring will be ·
conducted over the next five years to evaluate the natural wetland restoration process.
2.4.4 Groundwater
As mentioned under section 2.4.3, lime was applied at depth in the Drum Disposal excavation
area. The former Drum Disposal Area is approximately 35 feet upgradient of monitoring wells
MW-7S and MW-7D, which were installed during the Remedial Design. 5 In addition, 400
pounds of lime was placed at a ½-inch thickness around the perimeter of the well cluster (10 feet
by IO feet). All monitor and production wells located at the Site, with the exception of MW-7S
and MW-7D, were abandoned by a licensed well driller during June 18 -19, 2007. The first
annual monitoring will occur approximately six months from now, to allow time for the lime to
neutralize the shallow groundwater.
After the Final Inspection was conducted, Apex submitted a request to install a flow-through
trench halfway between the former Drum Disposal Area and the MW-7S & MW-7D well cluster.
The planned trench would be approximately 50 feet long and would extend a minimum of two
feet below the water table. The shallow well has a depth to water of approximately 5 feet so this
would result in a trench of 7 to IO feet if this condition exists at the proposed flow through trench
location. A minimum of 2000 pounds of pelletized lime would be installed in the trench prior to
backfilling to the surface with excavated material (Reilly, 2007a). This work was completed on
September 21, 2007, under the oversight of NC DENR. According to NC DENR, in addition,
approximately 2 feet thick layer of crushed shells was laid on top of the lime to act as a treatment
cell, prior to backfilling with native soils. This action was not required by the Amended ROD.
2.4.S Demobilization and Pre-Final Inspection
The construction work was completed and the contractor demobilized from the Site on July 3,
2007. Work was completed well in advance of the schedule outlined in the Remedial Action
4 Photo of bag oflime can be found in Appendix C.
5 Photo illustrating proximity of Drum Disposal Area to MW-7S and MW-7D can be found in Appendix C.
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Preliminary Close Out Report Reasor Chemical Company Site
Work Plan. The Pre-Final/Final Inspection occurred on July 26, 2007. No punch list items were
identified. Grass had already begun growing in the restored areas. Photographs are included in
Appendix C. No further remedial action construction activities are anticipated at this Site.
A Final Remedial Action Report will be prepared when all groundwater cleanup goals specified
in the 2007 Amended ROD have been achieved.
2.S Institutional Controls
Institutional Controls (!Cs) were required by the amended ROD. EPA, NC DENR, and the
current property owners have worked together negotiating language for the Declaration of
Perpetual Land Use Restrictions (DPLUR) which will be filed with the Office of the Register of
Deeds for New Hanover County. The DPLUR will be used to prevent human exposure to
contaminated groundwater on the Site property above cleanup goals specified in the 2007 ROD
Amendment. The only wells at or near the site which indicated contaminants of concern above
cleanup goals during the Rl/FS or RD activities are wells MW-7S and MW-7D (which are
located near the center of the Site property). Thus, the DPLUR is only necessary on the Site
property and not on other properties near the Site. Specifically, the DPLUR will prohibit the use
of surficial groundwater for any purpose on the Site property. The DPLUR will require that any
groundwater well or other device for access to groundwater on the Site property for any purpose
other than monitoring groundwater quality must include an isolation seal between the surficial
aquifer and the Peedee Formation aquifer located below. This declaration will be attached to the
title of the Site property and will remain enforceable by EPA and NCDENR regardless of
property ownership changes. These restrictions will remain in place until the groundwater
quality improves enough to allow for unrestricted use and unlimited exposure. This will occur
when the groundwater below the site meets groundwater cleanup goals specified in the 2007
ROD Amendment. A Site figure will be included with the DPLUR document. The site property
owners are responsible for implementing the IC, which is enforceable by NCDENR and EPA.
The declaration shall run with the land and shall be binding on all parties having any right, title
or interest in the Site or any part thereof, their heirs, successors and assigns.
The language in the document has been finalized. NC DENR also requires filing a Notice of
Inactive Hazardous Substance of Disposal Site constituting a survey plat map at the same time
the DPLUR is filed. The property owners had a plat map prepared, but revisions are needed. It
is anticipated that the DPLUR will be filed by December 31, 2007.
2.6 Redevelopment
The property owner does not have any definite plans on redevelopment of the Site at this time.
However, interest has been expressed in rezoning the property from heavy industrial to a mixture
of commercial and residential. The local newspaper reported that the property was under
consideration for use as a passive park. Because the residential cleanup goals specified in the
2007 ROD Amendment were achieved for soils, redevelopment options are unlimited with the
exception of shallow groundwater use.
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Preliminary Close Out Report Reasor Chemical Company Site
3.0 DEMONSTRATION OF CLEANUP ACTIVITY QA/QC
The construction activities were completed in compliance with the May 2007 Remedial Action
Work Plan-Revision 2, and the May 2007 Performance Standards Verification Plan-Revision
2, which includes the Field Sampling and Analysis Plan, as well as the Quality Assurance
Control Plan. Details are explained in the following subsections. The 2007 Amended ROD
revised cleanup goals for the Site. Cleanup Goals from the 2007 Amended ROD, the basis for
those goals, and the risks associated with those goals are presented in Table I.
Table 1 -Cleanu
Chemical of Concern Cleanup
Goal
Media: Soil
Benzo(a)pyrene 610 µg/kg
Benzo(b &/or k)fluoranthene 6,100 µg/kg
Dibenzo(a,h)anthracene 610 µg/kg
Antimony 30 mg/kg
Copper 2,700 mg/kg
Lead 400 mg/kg
Media: Sediment
Toluene 8,050 µg/kg
Methyl ethyl ketone 137 µg/kg
(3 and/or 4 )-methyl phenol 50 µg/kg
Total PAHs 13,660 µg/kg
Copper 197 mg/kg
Aluminum 16,000 µg/L
Beryllium 4 µg/L
Chromium 50 µg/L
Nickel 100 µg/L
Media: Surface water
Copper 7 µg/L
Iron 1000 µg/L
Lead 2.5 µg/L
Zinc 50 µg/L
Notes:
ATV= Alternate Toxicity Value
BHHRA = Baseline Human Health Risk Assessment
ERA = Ecological Risk Assessment
Goals, Basis, and Risk at Goal
Basis for Cleanup Goal
BHHRA
BHHRA
BHHRA
BHHRA
ERA Toxicity Tests
EPA guidance
ERA ATV
ERA ATV
ERA ATV
ERA ATV
ERA ATV
BHHRA
Federal MCL
State MCL
State MCL
NC Water Pollution Control Regulations
NC Water Pollution Control Regulations,
Clean Water Act
Clean Water Act
NC Water Pollution Control Regulations
HQ= Hazard Quotient (non-carcinogenic)
N/A ::: Not Applicable
Federal MCL = Safe Drinking Water Act (SWDA) Maximum Contaminant Level (MCL)
State MCL = North Carolina Administrative Coda, Subchapter 2L, Groundwater Classification and Standards
9
Risk at Cleanup Goal
Cancer risk= 1 x1ff5
Cancer risk = 1x10-5
Cancer risk= 1x10-5
HQ; 1
HQ; 1
N/A
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
HQ; 1
• • Preliminary Close Out Report Reasor Chemical Company Site
3.1 Surface Water
The Remedial Action Work Plan required one sample to be collected and analyzed for every
50,000 gallons of water treated. Samples were to be analyzed for the following contaminants of
concern prior to discharge: aluminum, copper, iron, lead, zinc, toluene, fluoranthene, and
phenanthene. According to a phone conversation with Bruce Reilly, Apex, the initial sample
indicated that the treatment system was effective. Therefore, the contractor proceeded with
treating and discharging contaminated pond surface water. However, the contractor did not wait
on receipt of analytical data prior to discharging the subsequent batches. According to Mr.
Reilly, the latter samples had concentrations of antimony, copper and lead which exceeded the
surface water cleanup goals specified in the 2007 ROD Amendment. The water was discharged
to the land surface, not to a surface water body. EPA has not received the surface water
treatment data from Apex yet. In late August 2007, the contractor returned to the Site and
collected surface soil samples in the area of spray irrigation. The results of the two soil samples
collected were less than the cleanup goals specified in the 2007 ROD Amendment. The
analytical results are included in Table 4 in Section 3.2.
3.2 Soil
The Performance Standards Verification Plan (PSVP) required that after soil excavation three
composite soil samples would be collected from the Drum Disposal Area, one composite soil
sample would be collected from the Pipe Shop Area, and one composite soil sample would be
collected from the Scrap Copper Area. The PSVP also required duplicate samples to be
collected from two of the soil excavations. A portable X-ray Fluorescence Spectrometer (XRF)
was also utilized during excavation of the Pipe Shop Area and the Scrap Copper Area. Samples
were screened with the XRF for copper, lead and antimony during the excavation process to aid
in determining whether cleanup goals had been achieved prior to collecting samples for
laboratory analysis. Tables 2 and 3 present a summary of analytical data from confirmation
samples that were collected after soil excavation. All results were well below the cleanup goals
specified in the 2007 ROD Amendment.
Table 2 -oil on 1rmat1on S C fi D ata or D rum Disposal Area
Cleanup Drum Orum Drum Drum
Chemical of Concern Disposal #1 Disposal #2 Disposal #3 Disposal Goal (CFDDS0-16) (CFDDS0-17) (CFDDS0-18) (Duplicate)
Semi-Volatile Organic Compounds (µglkg):
Benzo(a)pyrene 610 <420 <390 <410 <410
Benzo(b &/or k)fluoranthene 6,100 <420 <390 <410 <410
Dibenzo(a,h)anthracene 610 <420 <390 <410 <410
Metals (mg/kg):
Antimony 30 <6.4 <5.9 <6.3 <6.2
Copper 2,700 <2.5 <2.4 <2.5 <2.5
Lead 400 <3.2 <3.0 <3.1 <3.1
Notes:
< = constituent not detected above laboratory's reporting limit, which was less than the Cleanup Goal
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Preliminaiy Close Out Report Reasor Chemical Company Site
a e -01 on 1rma 10n aa or 1pe T bl 3 S ·1 C fi r D t f p· Sh op an dS crap C 0[ oer A rea
Scrap Scrap
Copper
Chemical of Concern Cleanup Pipe Shop Copper Duplicate Goal (CFCASO-(CFCASO-22) 24)
Semi-Volatile Organic Compounds (µglkg):
Benzo(a)pyrene 610 <400 <400 <420
Benzo(b &for k)fluoranthene 6,100 <400 <400 <420
Dibenzo(a,h)anthracene 610 <400 <400 <420
Metals (mg/kg):
Antimony 30 <6.0 <6.0 <6.3
Copper 2,700 7 <2.4 <2.8
Lead 400 6 3.1 <3.5
Notes:
< = constituent not detected above laboratory's reporting limit, which was less than the Cleanup Goal
As mentioned in Section 2.4.1, some treated water did not achieve surface water cleanup goals
specified in the 2007 ROD Amendment. Because the treated water was land applied, any
potential contamination discharged would have been to surface soils. In August 2007 the
contractor returned to the Site and collected two surface soil samples from the location that
treated surface water was discharged. Table 4 presents analytical data collected from that
sampling event. All results were well below the cleanup goals specified in the 2007 ROD
Amendment.
Table 4 -Soil Confirmation Data in area of Surface Water
A r \OD 1cat1on
Chemical of Concern Cleanup Goal Sample Sample
#CFWW-40 #CFWW-41
Volatile Organic Compounds (µglkg):
Methyl ethyl ketone nla <106 <220
Metals (mg/kg):
Antimony 30 <0.57 <0.73
Copper 2,700 12.7 14.8
Lead 400 10.2 17.8
Notes:
nla = A cleanup goal was not established in the ROD for this constituent in surface soll.
Sediment cleanup goal was 137 µg/kg.
<=indicates analyte was not detected at concentr~tions above the reporting limit.identified
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Preliminary Close Out Report Reasor Chemical Company Site
3.3 Sediment
The PSVP required that after sediment excavation, one composite sample would be collected
from the bottom of each of the excavated ponds and one composite sample would be collected
from the walls of Pond 2. In addition, one duplicate sample would be collected from one of the
ponds. Pond 3 was chosen for the duplicate sample. Results for all constituents except methyl
ethyl ketone and (3 and/or 4)-methylphenol were well below the cleanup goals specified in the
2007 ROD Amendment. Methyl ethyl ketone and (3 and/or 4)-methylphenol were not detected,
however, the laboratory's reporting limit exceeded the cleanup goal specified in the 2007 ROD
Amendment. Therefore, Apex returned to the Site during the week of August 27, 2007, cored
through the fill to the clay layer which indicated that base of excavation, and collected additional
samples from the four ponds. Preliminary results indicate that the contaminants were not
detected above the laboratory's reporting limit, however, the reporting limit for several samples
still exceed the cleanup goals specified in the 2007 ROD Amendment. Results of the original
and re-sampling events are summarized in Table 5.
Table 5 -Sediment Confirmation Data
Chemical of Concern Cleanup Pond 1 Pond 2 Pond 2 Pond 3 Pond 3 Pond4 Goal walls (Duplicate)
Volatile Organic Compounds (µglkg):
Methyl ethyl ketone 137 <96 <5.2001 <5,0001 <4,5001 <5,0001 <100
8/27/07 resample 137 <101 <103 NA <202 NA <9,240
Toluene 8,050 <4.8 3,800 <250 2,300 1,400 62
Semi-Volatile Organic Compounds (µglkg):
(3 and/or 4 )-methylphenol 50 <410 <420 <450 NA NA <420
8/27/07 resample 50 <404 <621 NA <395 NA NA
Benzo(a)pyrene 610 <410 <420 <450 <410 <420 <420
Benzo(b &for k)fluoranthene 6,100 <410 <420 <450 <410 <420 <420
Dibenzo(a,h)anthracene 610 <410 <420 <450 <410 <420 <420
lnorganics (mg/kg):
Antimony 30 <6.2 <6.4 <6.8 <6.2 <6.4 <6.4
Copper 197 <2.5 <2.5 3.2 4.2 <2.6 6.9
Lead 400 7.3 5.6 7.8 7.4 5.7 8.5
Notes:
' Detection limit exceeded ROD cleanup goal for that constituent due to dilution factor. Resampling occurred during week of B/27/07,
NA = Not analyzed
<=indicates analyte was not detected at concentrations above the reporting limit identified
Cleanup goals for both methyl ethyl ketone (also known as 2-butanone) and (3 and/or 4)-
methylphenol were Alternative Toxicity Values from the Ecological Risk Assessment. These are
considered very conservative numbers. For methyl ethyl ketone, the laboratory reporting limit
was below the cleanup goal for Ponds I, 2, and 4 in at least one of the sampling events. Pond 3 's
lowest detection limit was 202 µg/kg, which is only slightly higher than the cleanup goal of 137
µg/kg. For (3 and/or 4)-methylphenol, the detection limits for all ponds ranged from 395 to 621
µg/kg. The location of these samples is currently beneath at least one foot of clean soil.
12
•
Preliminary Close Out Report Reasor Chemical Company Site
On September 24, 2007, the Remedial Project Manager for the Site discussed this issue with
EPA Region 4 Ecological Risk Assessor, Sharon Thoms. Ms. Thoms stated that the cleanup
. goals established in the 2007 ROD Amendment are conservative and referred the RPM to a
document titled Toxicological Benchmarks for Screening Contaminants of Potential Concern for
Effects on Sediment-Associated Biota: 1997 Revision, which includes higher screening values.
The purpose of that document "is to present sediment benchmark data and discuss their use as
benchmarks for determining the level of toxicological effects on sediment-associated biota and to
briefly describe three categories of approaches to the development of sediment quality
benchmarks." Selected pages from that document are included in Appendix B.(Jones et al., 1997)
Table 3 of that document includes parameters regarding 2-butanone (methyl ethyl ketone). In
that table, it identifies the secondary chronic value for this chemical at 270 µg/kg and the lowest
chronic value benchmark for fish as 5,400 µg/kg. The document states, "Secondary chronic
values are intended to be conservative predictors of effects."And further, "Concentrations that
exceed Lowest Chronic Value benchmarks indicate a risk of real effects." (Jones et al., 1997).
As mentioned previously, the detection limits for the chemical were less than the cleanup goal
for sediment specified in the 2007 ROD Amendment for Ponds I, 2 and 4. The detection limit
for this chemical in Pond 3 was 202 µg/kg. Therefore, the concentration of methyl ethyl ketone
that may remain in Pond 3 sediments, does not present an ecological risk.
Table 2 of that document included Washington state sediment quality standards for 4-
methylphenol. There was not a specific listing for (3 and/or 4)-methylphenol. The standard
identified for 4-methylphenol was 670 µg/kg. The laboratory data was listed as 3+4-
methylphenol. The maximum detection limit for 3+4-methylphenol was 621 µg/kg, which is less
than the Washington state sediment quality standard for 4-methylphenol. Therefore, the
concentrations that may remain in pond sediments, should not present an ecological risk.
13
• • Preliminary Close Out Report Reasor Chemical Company Site
3.4 Quality Assurance/Quality Control
The construction activities were completed in compliance with the May 2007 Remedial Action
Work Plan -Revision 2, and the May 2007 Performance Standards Verification Plan -Revision
2 (PSVP), which includes the Field Sampling and Analysis Plan, as well as the Quality
Assurance Control Plan. The Quality Assurance/Control Plan required equipment blanks, trip
blanks, field blanks, duplicate samples, and matrix spike/matrix spike duplicates. Duplicate
sample results are included in the previous discussions. In an email dated September 12, 2007,
the project manager for Apex Companies, LLC stated:
"All of the samples called for in the PSVP were collected and analyzed. Apex has
. reviewed the lab reports 011 the blanks, duplicates and spike duplicates and has not found
any sample data that we believe indicates quality control problems with the lab. The
complete report and appendices will include all sample reports including the blanks,
duplicates and spike duplicates." (Reilly, 2007b)
The draft Interim Remedial Action Report was received by EPA on September 19, 2007. A
cursory review of the Quality Assurance/ Quality Control (QA/QC) data is consistent with
Apex's statement.
14
• • Preliminary Close Out Report Reasor Chemical Company Site
4.0 REMAINING ACTIVITIES AND SCHEDULE FOR SITE COMPLETION
The activities and schedule for site completion up through the preparation of the Final RA
Report and preparation of the Final Closeout Report are discussed below and summarized in
Table 6. These activities, when acceptably completed, will satisfy procedural and National
Contingency Plan (NCP) requirements for issuing the Final Closeout Report and reaching site
completion. The schedule for activities associated with deleting the site from the NPL, up
through publication of the Notice of Deletion from the NPL, are also noted in the following
Table.
All construction activities that constitute substantial construction completion for all remedial
components identified in the 2007 Amended ROD have been successfully implemented at the
Site. EPA and NCDENR conducted a pre-final inspection on July 26, 2007 for the Site's
remedial construction, and determined that the contractors have constructed the site remedy in
accordance with the Remedial Action Work Plan and specifications which were developed in
accordance with the 2007 Amended ROD for the Site.
Institutional controls will soon be implemented at the Site. Operation and maintenance (O&M)
and monitoring will continue to occur at the site to assure the site remains protective of human
health and the environment. O&M and monitoring will continue to occur in the groundwater
until all groundwater cleanup goals noted in the 2007 Amended ROD are met at the site. All
groundwater cleanup goals must be achieved and institutional controls established before a Final
Closeout Report can be prepared by EPA.
Tbl6R Tk a e -emammQ as s
Estimated Responsible
Task Comoletion Oraanization
Annual Groundwater Monitorinq annually PRP
lmolement ICs 12/31/2007 EPA/State/PRP
Determine Remedy is Operational
and Functional (O&Fl 3/31/2008 EPA/State/PRP
Annrove Interim RA Reoort 3/31/2008 EPA
1st Five-Year Review 6/4/2012 EPA/State/PRP
Monitor wetland restoration 6/4/2012 PRP
Pre-Certification Inspection 3/30/2035' EPA/State/PRP
Annrove Final RA Report 12/30/2035" EPA
Aoorove Final Close Out Reoort 12/30/2035" EPA
Delete Site from the NPL 9/30/2036' EPA
• These dates are extreme estimates. Achievement of groundwater cleanup goals
may be achieved sooner or later than the dates listed.
15
• •
Preliminary Close Out Report Reasor Chemical Company Site
5.0 SUMMARY OF REMEDIATION COSTS
The estimated cost to implement the remedy in the amended ROD was $560,774, which includes
Capital costs as well as annual O&M activities and Five-Year Reviews. The total Capital Costs
were estimated at $391,443. Annual O&M costs were estimated to be $7,560 in the amended
· ROD. The PRPs contracted with Apex Companies, LLC for a lump sum fee of$424,070 for
construction costs (Reilly, 2007c). There have been no O&M activities that have occurred yet.
Table 7 illustrates cost estimates from the 2007 ROD_ Amendment and actual expenditures.
Table 7 -Costs
ROD
Estimated Actual Difference
Cacital Costs $391,443 $424,070 $32,627
Annual O&M $7,560 TBD TBD
Notes: TBD = To Be Oetemilned. O&M has not yet occurred at
the Site.
6.0 FIVE-YEAR REVIEW
Pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) section 121(c), 42 U.S.C. § 9601 et seq., and EPA's Five-Year Review
Guidance (EPA, 2001 ); because this remedy will result in hazardous substances, pollutants, or
contaminants remaining on-site above levels that allow for unlimited use and unrestricted
exposure, a policy review must be conducted every five years after completion of remedial
action construction at the Site until the groundwater remedy achieves groundwater cleanup goals
specified in Table 47 of the 2007 ROD Amendment to ensure that the remedy is protective of
human health and the environment. The first Five-Year Review will be completed prior to June
4;2012. Reviews will continue at five year intervals until the Site is determined to be acceptable
for unlimited use/unrestricted exposure.
7.0 APPROVAL
(/ A~~ --;~
'----Ffanklin E. Hill, Director
Superfund Division
16
Date
• Preliminary Close Out Report Reasor Chemical Company Site
8.0 REFERENCES
Apex Companies, LLC, 2007a. Reasor Chemical Superfund Site, Interim Remedial Action and
Final Construction Report. September 2007.
Apex Companies, LLC, 2007b. Reasor Chemical Superfund Site, Performance Standards
Verification Plan. May 2007.
EPA, 2007. Amended Record of Decision, Reasor Chemical Co. Site. June I, 2007.
http://www.cpa.gov/superfund/sites/rods/fu I ltext/a200704000 1595.pdf}
EPA, 2001. Comprehensive Five-Year Review Guidance. EPA 540-R-01-007;
OSWER No. 9355.7-038-P; June 2001.
http://www.cpa.gov/superfund/accomp/5ycar/guidance.pdf
EPA, 2000. Close Out Procedures for National Priorities List Sites. EPA 540-R-98-016;
OSWER Directive 9320.2-09A-P; PB98-963223; January 2000.
http://www.epa.gov/superfund/programs/npl hrs/closeout/pdf/guidance.pdf
Jones et al., 1997. Toxicological Benchmarks for Screening Contaminants of Potential Concern
for Effects on Sediment-Associated Biota: 1997 Revision. (ES/ER/TM-95/R4)
http://www.hsrd.ornl.gov/ecorisk/tm95r4.pdf
Reilly, 2007a. E-mail Subject: FW: Reasor Lime Work. September 12, 2007, 3:38 p.m.
Reilly, 2007b. E-mail Subject: RE: Reasor Chemical Site -ps/sca duplicate? QA samples?.
September 12, 2007, 1:00 p.m.
Reilly, 2007c. E-mail Subject: Reasor Chemical Site -Remediation Costs. September 6, 2007,
2:40 p.m.
17
• • Preliminary Close Out Report Reasor Chemical Company Site
APPENDIX A
Site Figure
18
•
•
• •
Preliminary Close Out Report Reasor Chemical Company Site
APPENDIXB-
Select pages from
Toxicological Benchmarks for Screening Contaminants of
Potential Concern for Effects on Sediment-Associated Biota:
1997 Revision
20
•
Toxicological Benchmarks for Screening
Contaminants of Potential Concern
for Effects on Sediment-Associated Biota:
1997 Revision
D. S. Jones, LMER
G. W. Suter II, LMER
R. N. Hull, Beak Consultants, Ltd.
Date Issued-November 1997
Prepared for the
U.S. Department of Energy
Office of Environmental Management
under budget and reporting code EW 20
LOCKHEED MARTIN ENERGY SYSTEMS, INC.
managing the
Environmental Management Activities at the
East Tennessee Technology Park
ES/ER/TM-95/R4
Oak Ridge Y-12 Plant Oak Ridge National Laboratory
Paducah Gaseous Diffusion Plant Portsmouth Gaseous Diffusion Plant
under contract DE-AC05-84OR21400
for the
U.S. DEPARTMENT OF ENERGY
• •
PREFACE
The purpose of this report, Toxicological Benchmarks for Screening Contaminants of Potential
Concern for Effects 011 Sediment-Associated Biota.: 1997 Revision (ES/ER/fM-95/R4), is to present
sediment benchmark data and discuss their use as benchmarks for determining the level of toxicological
effects on sediment-associated biota and to briefly describe three categories of approaches to the
development of sediment quality benchmarks. This work was performed under Work Breakdown
Structure 1.4.12.2.3.04.05.04 (Activity Data Sheet 8304, "Technical Integration-Risk Assessment").
Publication of this document meets a milestone for the Environmental Restoration Risk Assessment
Program. 1bis report is an update of two prior reports (Jones et al. 1997; Jones et al. 1996; and Hull and
Suter 1994). It contains new benchmarks for freshwater sediments, equilibrium partitioning benchmarks
corrected to two significant figures, and all of the freshwater and estuarine benchmarks included in the
previous version.
V
• •
EXECUTIVE SUMMARY
A hazardous waste site may contain hundreds of chemicals; therefore, it is important to screen
contaminants of potential concern for the ecological risk assessment. Often this screening is done as part
of a screening assessment, the purpose of which is to evaluate the available data, identify data gaps, and
screen contaminants of potential concern. Screening may be accomplished by using a set of toxicological
benchmarks. These benchmarks are helpful in determining whether contaminants warrant further
assessment or are at a level that requires no further attention. lf a chemical concentration or the reported
detection limit exceeds a proposed lower benchmark, further analysis is needed to determine the hazards
posed by that chemical. lf, however, the chemical concentration falls below the lower benchmark value,
the chemical may be eliminated from further study.
The use of multiple benchmarks is recommended for screening chemicals of concern in sediments.
Integrative benchmarks developed for the National Oceanic and Atmospheric Administration and the
Florida Department of Environmental Protection are included for inorganic and organic chemicals.
Equilibrium partitioning benchmarks are included for screening nonionic organic chemicals. Freshwater
sediment effect concentrations developed as part of the U.S. Environmental Protection Agency's (EPA's)
Assessment and Remediation of Contaminated Sediment Project are included for inorganic and organic
chemicals (EPA 1996). Field survey benchmarks developed for the Ontario Ministry of the Environment
are included for inorganic and organic chemicals. In addition, EPA-proposed sediment quality criteria
are included along with screening values from EPA Region IV and Ecotox Threshold values from the
EPA Office of Solid Waste and Emergency Response. Pore water analysis is recommended for ionic
organic compounds; comparisons are then made against water quality benchmarks.
This report is an update of three prior rep_orts (Jones et al. I 997; Jones et al. 1996; and Hull and
Suter 1994). It contains new benchmarks for freshwater sediments, equilibrium partitioning benchmarks
corrected to two significant figures, and all of the freshwater and estuarine benchmarks included in the
prev10us vers10n.
xiii
• •
I I
Table 2. Washington state sediment quality standards
for ionizable organic compounds
(micrograms per kilogram dry weight)
Compound
Benzoic acid
Benzyl alcohol
Pentachlorophcnol
Phenol
2-Methyl phenol
4-Methyl phenol
2,4-Dimethyl phenol
Source: Ginn and Pastorak 1992
Washington state sediment
quality standard
650
57
360
420
63
670
29
3.2 FRESHWATER SEDIMENTS
3.2.1 EqP Benchmarks
The EPA has chosen the EqP approach for developing SQC for nonionic organics (EPA 19931).
This is also a methodology that ORNL supports for developing SQBs when bulk sediment
concentrations and WQBs are available.
The EqP approach requires a WQB, a Koc value, and a measured or assumed site-specific total
organic carbon (TOC) value. Because many chemicals do not have National Ambient Water Quality
Criteria (NAWQC), sets ofWQBs of varying conservatism have been developed at ORNL (Suter and
Tsao 1996); consult this publication, or its most recent revision, for a complete discussion of the aquatic
benchmarks and their uses. Secondary chronic values are intended to be conservative predictors of
effects. If concentrations exceed benchmarks that used the NAWQC, the chemicals must be
contaminants of concern because the NAWQC are applicable or relevant and appropriate requirements.
Concentrations that exceed Lowest Chronic Value benchmarks indicate a risk of real effects. Table 3 lists
available log I<,,. values for selected nonionic organic contaminants, sources of these values, calculated
log¾ values, and estimated SQBs corresponding to the conventional aqueous benchmarks; these SQBs
are normalized assuming I% TOC.
For polar organic chemicals, adsorption mechanisms other than hydrophobicity may significantly
increase the fraction of the chemical sorbed to the sediment particles (EPA 19931). Therefore, the
¾-based model is likely to overestimate the free, and therefore bioavailable, chemical concentration.
SQBs for selected polar nonionic organic chemicals are included in Table 3 as conservative benchmarks
and are denoted appropriately.
The bulk sediment contaminant concentrations measured at a site can be compared directly to the
SQBs presented in Table 3. It is recommended, however, that these benchmarks be adjusted by
multiplying the SBQ by the site-specific percent TOC. For example, the SQC for acenaphthene is 1300
µg/kg assuming 1% TOC and 13,000 µg/kg assuming 10% TOC (EPA 1993a). However, the
Table 3. Summary of EqP-derived sediment quality benchmarks for nonionic organic chemicals
corresponding to conventional aqueous benchmarks•
L-Owst chronic value
Secondary Nond.aphnid
Chemical Log Ko"'_. L-Og Koc NA WQC chronic chronic \lalue Fish Daphnids invertebrates
Acenaphthene 3.92 3.85 1300' 5300 470,000 16,000 • Acetone' -0.24 -0.24 8.7 3000 9.1
Anthracene 4.55 4.47 220 27 <620
Benzene 2.13 2.09 160 >120,000
Benzidine" 1.66 1.63 1.7 57
Benzo( a )anthracene 5.70 5.60 110 2600
Benzo(a)pyrene 6.11 6.01 140 3000
Benzyl alcohol' I.I I 1.09 1.1 73 N
BHC (lindane) 3.73 3.67 3.7 680 670 150
BHC (other) 3.80' 3.74 120 5200
Biphenyl 3.96' 3.89 1100
Bis(2-ethy\hexyl)phthalate 7.60'" 7.47 890,000
4-Bromophenyl phenyl ether 5.00 4.92 1200 • Butylbenzyl phthalate 4.84 4.76 11,000
2-Butanone' 0.29' 0.29 270 5400 27,000
Carbon disulfide 2.00 1.97 0.85 8800 230
Carbon tetrachloride 2.73 2.68 47 9500 27,000
Chlordane 6.32 6.21 2800 26.000 260,000 18,000
Chlorobenzene 2.86 2.81 410 7800 97,000
Chlorofonn 1.92 1.89 22 960 3500
p,p'-DDD 6.10 6.00 110 17.000
Chemical Log Ko~ Log Koc
Tetrachloroethene 2.67 2.62
Toluene 2.75 2.70
Tribromomethane 2.35' 2.31
1.2,4-Trichlorobenzene 4.01 3.94
I ,I, I-Trichloroethane 2.48 2.44
1, 1,2· Trichloroethane 2.05 2.02
Trich\oroethene 2.71 2.66
Vinyl acetate 0.73 0.72
Xylene 3.IY 3.08
m-Xylene 3,20 3.15
Table 3 (continued)
Secondary
NA WQC <"hronic chronic value
410
50
650
9600
30
1200
220
0.84
160
25
Fish
3500
6400
9600
9700
51,000
42
740,000
Lo¥,cst chronic value
Dapbnids
3200
130,000
19,000
33,000
Nondaphnid
invertebnatcs
"Conventional aqueous benchmarks are presented in Suter and Tsao (1996). EqP = equilibrium partioning. All sediment benchmarks are in µglkg and are estimated to
two significant figures assuming I% TOC. Estimated sediment quality benchmarks greater than I 0% ( I 00,000,000 µg/kg) are not included because such concentrations
are assumed to be exceedingly unlikely under natural conditions [applies to bis(2-ethylhexyl)phtha\ate and di-n-octylphthalate].
&Log Kow values are from EPA ( 1995a), except where noted otherwise.
'Denotes proposed EPA sediment quality criteria.
't>enotes polar nonionic organic compounds, for which the EqP model is likely to provide a conseivative estimate of exposure.
'Most conservative {i.e., lowest) recommended \'alue for re-poned configurations. BHC (other) is lowes1 of alpha-, beta-, and de\ta-BHC, only.
1Source is EPA ( 1995b).
'Source is search of Syracuse Research Corporation, Environmental Sciences Center's on-line Experimental Log P Database conducted on June 7, 1996.
hSource is ATS DR (1989).
•
u,
•
•
Preliminary Close Out Report
APPENDIXC
Site Photographs
27
•
Reasor Chemical Company Site
Preliminary Close Out Report
Before
Remedial
Action
June 2004
After"°-
Remedial
Action
July 26, 2007
• •
Reasor Chemical Company Site
Drum Disposal Area
28
• •
Preliminary Close Out Report Reasor Chemical Company Site
Photo taken by Samantha Urquhart-Foster, EPA, on June 26, 2007
29
• • Preliminary Close Out Report Reasor Chemical Company Site Drum Disposal Area in Relation to Monitorin2 Wells MW-7S and MW-7D Yellow posts surround wells in background; matting and new grass cover lime applied to subsurface. Photo taken by Samantha Urquhart-Foster, EPA, on July 26, 2007. 30
• •
Preliminary Close Out Report Reasor Chemical Company Site
Roll of Geotextile Fabric
Natural material woven into a biodegradable mat for erosion control and for promotion of seed germination
Photo taken by Samantha Urquhart-Foster, EPA, on June 26, 2007
31
• •
Preliminary Close Out Report Reasor Chemical Company Site
.
Orange flags indicate boundary oflnvestigation Derived Waste (IDW) drum storage area prior to
remedial action. Drums were removed from the Site during the remedial action.
(Photo taken July 26, 2007 by Samantha Urquhart-Foster, EPA)
32
Preliminary Close Out Report Before Remedial Action June 2004 After Remedial Action July 26, 2007 • • Reasor Chemical Company Site_ Pi1 No Photo Available 33
Preliminary Close Out Report
Before
Remedial
Action
March 2003
After
Remedial
Action
July 26, 2007
• •
Reasor Chemical Company Site
34
• • Preliminary Close Out Report Reasor Chemical Company Site Surface Water Treatment System Photo taken by Samantha Urquhart-Foster, EPA, on June 26, 2007 35
Preliminary Close Out Report
Before
Remedial
Action
March 2003
After
Remedial
Action
July 26, 2007
• •
Reasor Chemical Company Site
Pond 1
36
• •
Preliminary Close Out Report Reasor Chemical Company Site
Pond 1 Confirmation Sample Collection
Photo taken b Samantha Ur uhart-Foster, EPA, on June 26, 2007
Sediment excavation extended to clay liner. Photograph of Apex employees collecting
confirmation sample at the base of Pond 1 excavation, prior to restoration.
37
Preliminary Close Out Report
Before
Remedial
Action
March 2003
After
Remedial
Action
July 26, 2007
• •
Reasor Chemical Company Site
Pond 2
38
Preliminary Close Out Report
r
I
I
I
Before
Remedial
Action
March 2003
After
Remedial
Action
July 26, 2007
•
Reasor Chemical Company Site
Pond 3
39
Preliminary Close Out Report
Before
Remedial
Action
March 2003
After
Remedial
Action
July 26, 2007
•
Reasor Chemical Company Site
Pond4
40