Loading...
HomeMy WebLinkAboutNCD986187094_20070901_Reasor Chemical Company_FRBCERCLA CR_Preliminary Close Out Report-OCRf'o.-the l?li§Ol? Ctil:MICA.L COMJ>A~~ §IT~ C.&.§TLI: Ii&. -»-1:. "-1:W li&."-OVl:11 cou~ • "-Ol!Tt1 C.&.1,0LI"""" U.S. l:~l?Oi-.lMl:i-.lTA.L J)~OTl:CTIOi-.1 461:i-.lC.,.., ~1:£,IOi-.l 4 A. T~ A.9 61:0~£,14 • • 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 1 • • 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. 2 • • 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. 3 • • 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 • 4 • • 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 5 • • 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. 6 • • 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. 7 • • 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. 8 • • 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 10 • • 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 11 • • 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