NCD062555792_20060602_Sigmons Septic Tank Service_FRBCERCLA FS_Remedial Investigation Feasibility Study 2001 - 2006-OCR

•• BLACK & VEATCH
building a world of difference••
ENERGY WATER INFORMATION GOVERNMENT
RAC Contract Number 68-W-99-043
Work Assignment No. 340-RJCO-A44F
Ms. Beverly Stepter
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
•
Subject: Final Feasibility Study Report -Sigmons Septic Tank Site, Operable
Unit I, Statesville, Iredell County, North Carolina
Dear Ms. Stepter:
Please find enclosed five copies of the Final Feasibility Study Report -Sigmons Septic Tank Site,
Operable Unit /, Statesville, Iredell County, North Carolina, dated June 2006. As requested, an
additional copy of this document has been forwarded to Mr. Nile Testerman with the State of North
Carolina. This submittal addresses and incorporates both EPA and State of North Carolina
comments and risk management discussions and decisions regarding the previous version (Revision
0) of the report dated March 2006.
Please call me at [phone] or email me at [e-mail] if you have any questions or
require additional information.
Enclosures
cc: Janice Spady, EPA Region 4
Robert Stern, EPA Region 4
Deborah Hoover, EPA Region 4
Sincerely,
BLACK & VEATCH Special Projects Corp. fi._;-,-, fg~.5-
Tim Eggert
Project Manager
Joseph Slykcrman, Black & Veatch
Harvey Coppage, Black & Veatch
Adrian Gonzalez, QEP, Black & Veatch
Project File
Black & Veatch Special Projects Corp., 1145 Sanctuary Parkway• Suite 475, Alpharetta. GA 30004 USA• Telephone [phone] • Fax: [phone]
ENERGY WATER INFORMATION GOVERNMENT
RAC Contract Number 68-W-99-043
Work Assignment No. 340-RICO-A44F
Ms. Beverly Stepter
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
• r.=:fo)~rn;-;::;@~1g--::-o ~w ~=-~--.
ITT) JUN O 7 2006 lW
SUPERFUND SECTION
BVSPC Project 048340.0112
June 6, 2006
Subject: Replacement Pages, Final Feasibility Study Report -Sigrnons Septic Tank Site, Operable Unit I, Statesville, Iredell County, North Carolina
Dear Ms. Stepter:
Please find enclosed five copies of the replacement pages for the Final Feasibility Study Report -Sigmons Septic Tank Site, Operable Unit I, Statesville, Iredell County, North Carolina, dated June 2006. As requested, an additional copy of these replacement pages have been forwarded to Mr. Nile Testcnnan with the State of North Carolina. This submittal addresses and incorporates both EPA and State of North Carolina comments on the aforementioned document received via teleconference on June 5, 2006.
Please call me at (770) 52 1-81 IO or email me at [e-mail] if you have any questions or require additional information.
Enclosures
cc: Janice Spady, EPA Region 4
Robert Stem. EPA Region 4
Deborah Hoover, EPA Region 4
Sincerely,
BLACK & VEATCH Special Projects Corp . .,,,1. / C-~ /,I /?1 <e-3:y✓
Tim Eggert
Project Manager
Joseph Slykennan, Black & Veatch
Harvey Coppage, Black & Veatch
Adrian Gonzalez, QEP, Black & Veatch
Project File
Black & Veatch Special Projects Corp • 1145 Sanctuar1 Parkway• St:ite 475 • Alpharetta, GA 30004 USA· Telephone: [phone] • fax [phone]"
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
Table of Contents
(Continued)
•
Scction TOC
Revision No. I
Junt: 2006
Pagc 2 of3
Page No. 3.0 Identification, Screening, and Evaluation of Technologies and Process Options ................. 3-1
3. I General Response Actions ............................................................................................... 3-l
3.2 Preliminary Screening of Technologies and Process Options ......................................... 3-3
3.3 Evaluation of Retained Technologies and Process Options ............................................ 3-5
4.0 Development and Screening of Alternatives ........................................................................ .4-1
4.1 Soil Alternatives Analysis ............................................................................................... 4-l
4.1.1 Alternative I -No Action ..................................................................................... .4-2
4.1.2 Alternative 2 -Excavation and Onsite Treatment with Solidification/
Stabilization, and Onsite Disposal of Treated Waste ............................................ .4-3
4.1.3 Alternative 3 -Excavation and Onsite Treatment with Solidification/
Stabilization and Offsite Disposal of Treated Waste ............................................ .4-5
4.2 Screening of Soil Alternatives for Further Evaluation ................................................... .4-7
4.2.1 Effectiveness .......................................................................................................... 4-7
4.2.2 lmplementability ..................................................................................................... 4-7
4.2.3 Cost ......................................................................................................................... 4-7
4.3 Selection of Soil Alternatives for Further Evaluation .................................................... .4-7
5.0 Detailed Analysis ofAlternatives .......................................................................................... 5-l
5.1 Analysis of Soil and Sediment Alternatives .......................................................................... 5-5
5.1.1 Alternative I -No Action ...................................................................................... 5-6
5.1.2 Alternative 2 -Excavation, Onsite Treatment with Solidification/
Stabilization, and Onsite Disposal of Treated Waste ............................................. 5-7
5.1.3 Alternative 3 -Excavation, Onsite Treatment with Solidification/
Stabilization, and Offsite Disposal of Treated Waste .......................................... 5-I0
6.0 Comparative Analysis of Alternatives ................................................................................... 6-l 7.0 References ............................................................................................................................ 7-l
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Section 4
Revision No. I
June 2006
Page 3 of 7
MITN of contaminants at the site. Monitoring proposed under this alternative would allow EPA
to assess the ongoing threats to human health and the environment posed by the site.
4.1.1.3 Implementability. The only task which would require implementation under this
alternative is the periodic media monitoring at the site. This alternative could be easily
implemented since monitoring equipment is readily available and procedures are in place.
4.1.1.4 Cost. Minimal costs are associated with this alternative relative to other remedial
action alternatives. No capital costs are associated with this alternative. There will be annual
O&M costs for media sampling associated with the monitoring.
4.1.2 Alternative 2-Excavation and On-Site Treatment With Solidification/
Stabilization and On-Site Disposal of Treated Waste
4.1.2.1 Description. Contaminated soil throughout the site would be excavated and
consolidated. Confirmation sampling and analysis would be performed to ensure that the
cleanup goals are met for all contaminants.
It is assumed that 25 percent of the contaminated soil will require treatment prior to land
disposal. Solidification/Stabilization (S/S) technology would be used to treat the portion of
highly contaminated soil (assume 25 percent total). Contaminants within soil would be
physically bound or enclosed within a stabilized mass (solidification), or chemical reactions
would be induced between a stabilizing agent and the contaminant to reduce its mobility
(stabilization). S/S treatment technologies include the addition of cement, lime, pozzolan, or
silicate-based additives, or chemical reagents that physically or chemically react with the
contaminant. Once treated and confirmed to be nonhazardous, the soil would be consolidated
and disposed of in an onsite, unlined excavation. The onsite disposal area would be about 300
feet long, 200 feet wide and 4.25 feet deep. A I-foot soil cover consisting of uncontaminated
soil excavated from the disposal area would be placed over the disposal cell. A 6-inch topsoil
layer would be placed over the entire site.
The components of this alternative are outlined as follows:
• Excavation of contaminated soil (8,600 yct3) plus an additional 400 yct3 associated with existing onsite
debris piles for a total of9,000 yct3.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Opi..:rablc Unit l
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Sili.;
•
St.:ction 4
Revision No. I
June 2006
Page 4 of 7
• Confirmation sampling and analysis of the excavated areas to ensure that the cleanup goals are met.
• Stabilization or solidification of highly contaminated soil (approximately 2,925 yd').
• Excavation of onsite disposal area (9, I 00 yd').
• Compaction of 9, I 00 yd3 of waste; assuming a 5% increase m soil volume due to
stabi Ii zation/so I id i fication.
• Backfill of clean soil into areas where contaminated soil and sediment were removed (9,000 yd\
• Place a I-foot clean soil cover over the disposal site (2,200 yd\
• Place a 6 inch topsoil cover and grass seeding over disposal cell and soil excavation areas (3.5 acres).
• Land use/deed restrictions and fencing.
Alternative 2 would eliminate direct con~act with contaminated media, eliminate onsite physical
hazards, and eliminate contaminant migration to groundwater and surface water from the site.
The final treatment system would depend upon the outcome of treatability testing and would be
determined during the remedial design phase. The fixed material would be subjected to SPLP
testing to determine if treatment has been effective, prior to placement in the excavated disposal
area.
Treatability testing may be required to demonstrate contaminant immobilization for this
treatment process and to help determine the volume increase caused by the
solidification/stabilization process.
Deed restrictions may be placed on the site while the remedial action takes place. Monitoring
would be required to assess t~e effectiveness of the remedial action.
4.1.2.2 Effectiveness Under this alternative, contaminated media would be treated and
converted to a nonhazardous, nonleachable material and buried on site. Migration of hazardous
contamination to groundwater would be eliminated because the treated, buried material would
effectively bind or bond the contaminants, preventing leaching and contaminant migration. This
combination of technologies would ensure that the selected treatment system would rcmediate
surface soil and sediment contamination to concentrations meeting remediation goals, and RAOs
would be met. Excavation and onsite treatment permanently eliminates the long-term health and
environmental risks at the site, as well as reducing contaminant mobility.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
• •
Final Fcasibility Study Report -Operable Unit l
EPA Contract No. 68-W-99-043
Section 4
Revision No. I
Junt: 2006
Page 5 of 7
Work Assignment No. 340-RICO-A44F
Sigmon's Scptic Tank Site
4.1.2.3 Implementability. Treatment of contaminated soil and sediments is offered by
numerous vendors. Onsite treatment utilizes standard construction practices and material
handling equipment. No significant construction issues are expected to be encountered.
Treatment of the contaminated waste will likely increase the volume of the waste soil and
sediment material; however, slight volume reductions may occur when some chemical reagents
are used to treat the material. Typical volume increases range from about 5 percent to as high as
I 00 percent, depending upon the treatment method used. An increase in the volume of the
treated waste material will have an impact on the disposal volume required. Calculations used in
the development of this alternative utilized a volume increase estimate of5 percent.
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
decontamination activities required for equipment and on-site workers. Containment and
treatment or disposal of these wastewaters may be required. Depending upon the treatment
methodology selected, the wastewater may be able to be utilized in the soils treatment process.
4.1.2.4 Cost. Moderate to high costs are associated with this alternative relative to other
remedial action alternatives. Typical expenditures would include capital costs for equipment and
construction of the treatment system, as well as excavation.
4.1.3 Alternative 3-Excavation and On-Site Treatment With Solidification/
Stabilization and Off-Site Disposal of Treated Waste
4.1.3.1 Description. Alternative 4 is similar to Alternative 3 except that the S/S treated soil
and sediment will be disposed offsite. The specific components of this alternative are outlined
as follows:
•
•
•
Excavation of contaminated soil (8,600 yd3) plus an additional 400 yct3 associated with existing
onsite debris piles for a total of9,000 yd3•
Confirmation sampling and analysis of the excavated areas to ensure that the cleanup goals are met.
Stabilization or solidification of highly contaminated soil (approximately 2,925 yd3) •
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
II
I
•
Final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RfCO-A44F
Sigmon's Septic Tank Site
•
Section 4
Revision No. I
June 2006
Page 6 of 7
• Off-site disposal of the treated material at a nonhazardous disposal facility 11,846 yd3 (assuming a
5 percent increase in volume during treatment).
• Backfill of clean soil into areas where contaminated soil and sediment were removed (9,000 yd\
• Place a 6 inch topsoil cover and grass seeding over the soil excavation areas (2.5 acres) .
Alternative 3 would eliminate direct contact with contaminated media, eliminate onsite physical
hazards, and eliminate contaminant migration to groundwater and surface water from the site.
Deed restrictions may be placed on the site while the remedial action takes place. Monitoring
would be required to assess effectiveness of the remedial action.
4.1.3.2 Effectiveness. Under this alternative, contaminated media would be treated and
converted to a nonhazardous, nonleachable material and transported to an offsite disposal
facility. Migration of hazardous contamination would be eliminated because the material
containing contaminant concentrations above the cleanup goals would be treated and removed
from the site. This combination of technologies would ensure that the selected treatment system
would remediate surface soil to concentrations meeting remediation goals, and RAOs would be
met. Excavation and onsite treatment with offsite disposal permanently eliminates the long-term
health and environmental risks at the site. This alternative would ensure that the surface soil and
sediment concentrations would meet remediation goals and RAOs.
4.1.3.3 Implementability. Treatment of contaminated soil and sediment is offered by
numerous vendors. Onsite treatment utilizes standard construction practices and material
handling equipment. No significant construction issues are expected to be encountered.
Implementation of this process option is considered technically feasible and could be readily
implemented. Access to Subtitle D facilities also is available.
Treatment of the contaminated waste will likely increase the volume of the waste soil and
sediment material; however, slight volume reductions may occur when some chemical reagents
are used to treat the material. Typical volume increases range from about 5 percent to as high as
I 00 percent, depending upon the treatment method used. An increase in the volume of the
· treated waste material will have an impact on the disposal volume required. Calculations used in
the development of this alternative utilized a volume increase estimate of 5 percent.
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Section 4
Revision No. I
June 2006
Page 7 of 7
decontamination activities required for equipment and on-site workers. Containment and
treatment or disposal of these wastewaters may be required. Depending upon the treatment
methodology selected, the wastewater may be able to be utilized in the soils treatment process.
As is the case for Alternative 2, treatability testing may be required to demonstrate contaminant
immobilization for this treatment process and to help determine the volume increase caused by
the solidification/stabilization process.
4.1.3.4 Cost. High costs are associated with this alternative, as a result of offsite disposal
costs and transportation of the waste to a disposal facility. Capital costs include equipment for
excavation of the contaminated material and the purchase of clean fill. In addition, monitoring
costs associated with excavation verification are realized costs.
4.2 Screening of Soil Alternatives for Further Evaluation
4.2.1 Effectiveness
Alternative I is not effrctive in achieving any of the RAOs. Alternative 2 can partially meet
RAOs by reducing risks associated with exposure pathways; however, at least some
contaminated material still remains onsite. Alternative 3 is potentially effective in achieving
RAOs.
4.2.2 Implementability
All of the alternatives are implementable. Alternative 1 is easiest to implement, followed by
Alternatives 3 and 2.
4.2.3 Cost
Alternative I is the least costly of all of the alternatives, followed by Alternatives 2 and 3.
4.3 Selection of Soil Alternatives for Further Evaluation
Alternative l (no action) is retained for detailed analysis as required by the NCP. This
alternative serves as a baseline for decision makers to evaluate the other alternatives .
. Alternatives 2 and 3 are retained for further consideration since they can achieve RAOs through
treatment.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility SLUdy Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignmi.:nt No. 340-RICO-A44F
Sigmon's Septic Tank Site
Cost
•
Section 5
Revision No. 1
June 2006
Pagt: 7 of 12
The total present worth cost for this alternative 1s approximately $78,000. Detailed cost
estimates are presented in Appendix A.
5.1.2 Alternative 2-Excavation, Onsite Treatment With Solidification/
Stabilization, and Onsite Disposal of Treated Waste
Overall Protection of Human Health and the Environment
Successful implementation of this alternative would eliminate risks to human health and the
environment and meet the removal action objectives by (I) eliminating exposure of residents and
trespassers to waste material by direct contact and airborne migration, (2) eliminating exposure
of trespassers to direct contact with on-site physical hazards, and (3) eliminating the migration of
contaminants to groundwater and surface water. The threat of direct human exposure to
contaminated waste and physical hazards would be eliminated by this alternative. Treatment of
the waste material would eliminate contaminant exposure through the receptor routes of
ingestion and inhalation. It is assumed that 75 percent of the contaminated soil will be classified
as non-hazardous m·aterial and the remaining 25 percent of the contaminated soil would be
treated and converted to a nonhazardous material. Waste immobilized by treatment or removed
by decontamination would eliminate contaminant migration from the site.
Compliance with ARARs
If the treated soils are disposed on site, a cap consisting of at least 6 inches of asphalt or at least
12 inches of compacted soil is required. The other standards of the State of North Carolina
included in Table 2-5, Water Quality Criteria Standards and Water Pollution Control
Regulations, will be complied with if stabilization precludes leaching hazardous constituents
from the solidified or stabilized mass.
Long-Term Effectiveness and Permanence
If the disposal area is classified as a Class II disposal facility, the area may have to be maintained
to ensure that it continues to perform as designed; consequently, monitoring, inspection, and
maintenance would be required. The soil cover area would be susceptible to settlement, ponding
of surface water, erosion, and disruption of cover integrity by deep-rooting vegetation and
burrowing animals. However, the cover would be periodically inspected, and required
maintenance could be implemented.
If the SSTS is not classified as a Class II disposal facility; monitoring, inspection, and
maintenance may not be required. Treatment reagents arc typically tested by the Multiple
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's St:ptic Tank Siti.:
•
Section 5
R-:vision No. I
June 2006
Page 8 of12
Extraction Procedure (MEP, SW-846 Method 1320) to measure long-term stability. The test is
. intended to approximate leachability under acidic conditions over a 1,000-year time frame.
Based on successful completion of bench-scale testing that would include MEP analysis, this
alternative is expected to provide adequate long-term effectiveness and permanence. Access
restrictions such as land use controls and fencing may be required to prevent land uses
incompatible with the site.
Reduction of MITIV Through Treatment
The primary objective of this alternative is to reduce contaminant toxicity and mobility through
treatment; contaminant volume would not be reduced. Contaminant toxicity would be reduced
by altering the physical or chemical structure of the contaminant into a nonhazardous material.
Contaminant mobility would be reduced by binding or bonding the contaminant into a
nonleachable form that would eliminate contaminant migration from the site. Contaminant
mobility is expected to be reduced to an extent that would result in overall risk reduction from all
pathways and exposure routes.
Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal. Short-
term impacts are associated with excavation, consolidation, and treatment of waste soil and
sediment; however, these potential, short-term impacts would be mitigated during the
construction phase.
If the excavated material is dry, on-site workers will be exposed to waste soil dust during
excavation and consolidation activities. Ingestion of dust could involve some health effects
because of the high level of metals in waste soils.
Onsite workers would be adequately protected from short-term risks by using appropriate
personal protective equipment and by following proper operating and safety procedures.
However, short-term air quality impacts to the surrounding environment may occur during waste
consolidation and grading. Dust emissions would be monitored at the property boundaries.
Fugitive dust emissions would be controlled by applying water as needed to surfaces receiving
heavy vehicular traffic or in excavation areas. A measurable, short-term impact to the
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operable Unit l
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Si.:ction 5
Revision No. 1
June 2006
Page 9 of 12
surrounding area would include increased vehicular traffic and associated safety hazards,
potential dust generation, and noise.
lmpleme11tabi/ity
Treatment of contaminated soil and sediment is offered by numerous vendors. On-site treatment
utilizes standard construction practices and material handling equipment. No significant
construction issues are expected to be encountered.
Treatment of the contaminated soil will likely increase the volume of the waste soil material;
however, slight volume reductions may occur when some chemical reagents are used to treat the
material. Typical volume increases range from about 5 percent to as high as I 00 percent,
depending upon the treatment method used. An increase in the volume of the treated waste
material will have an impact on the disposal volume required. Calculations used in the
development of this alternative utilized a volume increase estimate of 5 percent.
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
decontamination activities required for equipment and on-site workers. Containment and
treatment or disposal of these wastewatcrs may be required. Depending upon the treatment
methodology selected, the wastewater may be able to be utilized in the soils treatment process.
The on-site disposal area for the treated waste may be classified as a Class II disposal facility. If
so, the substantive requirements of the Solid Waste Processing and Disposal (SWPD) rule
regarding Class II disposal facilities would apply to the site.
All services and materials for this alternative are readily available.
Cost
The total present worth cost for this alternative is approximately $2 million. Estimated capital
costs are $ l. 75 million and estimated O&M costs are $268,000. Detailed cost estimates are
presented in Appendix A.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
final Feasibility Study Report -Operable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Section 5
Revision No. I
June 2006
Page 10ofl2
5.1.3 Alternative 3-Excavation, On-Site Treatment With Solidification/
Stabilization, and Off-Site Disposal of Treated Waste
Overall Protection of Human Health a11d the E11viro11me11t
Successful implementation of this alternative would eliminate risks to human health and the
environment and meet the RAOs by (1) eliminating exposure of residents and trespassers to
waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers
to direct contact with on-site physical hazards, and (3) eliminating the migration of contaminants
to groundwater and surface water. The threat of direct human exposure to contaminated waste
and physical hazards would be eliminated by this alternative. Treatment and removal of the
waste material would eliminate contaminant exposure through the receptor routes of ingestion
and inhalation. It is assumed that 75 percent of the contaminated soil will be classified as non-
hazardous material and the remaining 25 percent of the contaminated soil would be treated and
converted to a nonhazardous material. The treated and untreated contaminated soil would be
transported to an off-site disposal facility. Removal of waste would mitigate contaminant
migration from the site.
Complia11ce with ARARs
Transportation of treated soils would be in accordance with applicable Department of
Transportation (DOT) hazardous material regulations. Disposal at a RCRA-permitted Subtitle D
landfill would be in compliance with ARARs.
Lo11g-Term Effectiveness a11d Perma11e11ce
Treatment and removal of the waste material would not require monitoring, inspection, or
maintenance for the site. Treatment reagents are typically tested by MEP SW-846 Method 1320
to measure long-term stability. The test is intended to approximate leachability under acidic
conditions over a 1,000-year time frame. Based on successful completion of bench-scale testing
that would include MEP analysis, this alternative is expected to provide adequate long-term
effectiveness and permanence. Access restrictions such as land use controls and fencing would
likdy not be required.
Reductio11 ofll1/T/V Through Treatme11t
The primary objective of this alternative is to reduce contaminant toxicity and mobility through
treatment; contaminant volume would not be physically reduced. Contaminant toxicity would be
reduced by altering the physical or chemical structure of the contaminant into a nonhazardous
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Opcrable Unit I
EPA Contract No. 68-W-99-043
Work Assignment No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Section 5
Revision No. l
June 2006
Page II ofl2
material. Contaminant mobility would be reduced by binding or bonding the contaminant into a
nonleachable form. Subsequent removal would mitigate contaminant migration from the site.
Contaminant volume would not be physically reduced under this alternative.
Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal. Short-
tern1 impacts are associated with excavation, consolidation, and treatment of waste soil;
however, these potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-site workers will be exposed to waste soil dust during
excavation and consolidation activities. Ingestion of dust could involve some health effects
because of the high level of metals in waste soil.
On-site workers would be adequately protected from short-term risks by usmg appropriate
personal protective equipment and by following proper operating and safety procedures.
However, short-term air quality impacts lo the surrounding environment may occur during waste
consolidation and grading, and lra?sportation of treated waste for off site disposal. Monitoring of
dust emissions would be monitored at the property boundaries. Fugitive dust emissions would
be controlled by applying water as needed to surfaces receiving heavy vehicular traffic or in
excavation areas. A measurable, short-term impact to the surrounding area would include
increased vehicular traffic and associated safety hazards, potential dust generation, and noise.
I mp/ementability
Treatment of contaminated soil and sediment is offered by numerous vendors. On-site treatment
utilizes standard construction practices and material handling equipment. No significant
construction issues are expected to be encountered.
Treatment of the highly contaminated soil will likely increase the volume of waste soil material;
however, a slight volume reduction may occur if a chemical reagent is used to treat the material.
Typical volume increases range from about 5 percent to as high as 100 percent, depending upon
the treatment methodology used. An increase in the volume of the treated waste material will
have an impact on the transportation costs to a disposal facility. Calculations used in the
development of this alternative assume a volume increase of 5 percent.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
Final Feasibility Study Report -Operabk Unit I
EPA Contract No. 68-W-99-043
Work Assignmr.:nt No. 340-RICO-A44F
Sigmon's Septic Tank Site
•
Section 5
Rt;vision No. I
June 2006
Page 12 of 12
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
decontamination activities required for both equipment and on-site workers. Containment and
treatment or disposal of these wastewaters may be required. Depending upon the treatment
methodology selected, the wastewater may be able to be utilized in the soils treatment process.
No state or federal permits are expected to be required; however, advance consultation should
occur in planning the action to ensure that all involved agencies are allowed to provide input.
All services and materials for this alternative are readily available.
Cost
The total present worth cost for this alternative is approximately $2.19 million. Estimated
capital costs are $2.16 million and estimated O&M costs are $29,000. Detailed cost estimates
are presented in Appendix A.
-
Remedial
Alternative
1 -No Action
2 -Excavation,
Treatment With
Solid1f1cation/
Stabilization and
Onsite Disposal
3 --Excavation,
Treatment with
Solidrfcalion/Stabdiza
!Ion and Offs1te
Disposal in Subtitle D
LandfiU
---------- ----
Threshold Criteria
Overall Protection of Compliance with Long-Term Human Health and the ARAR, Effectiveness and Environment Permanence
Does not eliminate exposure Chemic.ahpecitic The contaminated matenal pa1hways. or reduce the level ARARs are not is a Jong-term impact. The of risk. Does not hmit met. location-remediation goals are not migration of or remove and action-met. contaminants. spec1f1C ARARs
do not apply.
Eliminates exposure ARARs are met Long-term public health pathways and reduces the through threats associated with level ol risk. Removes direci excavation, onsite surlace soil are greatly exposure to contamination tn,atment, and reducea. Groundwater is ana eliminates further ons1te disposal. further protected through migration. the immobilization of the
contaminants in the soil.
Elimmates exposure ARARs are met Long-term public hea!th pathwar-, ano reduces the through threats associated with level of risk. Removes excavation, onS1te surface soil are greatly contamination and el"1minates treatmenl. and reduced. Groundwater further migration. offsite disposal. would also be protected
through removal of the
source contamination.
Table 5-1
Summary of Soil Alternatives Evaluation
Sigmons Septic Tank Site
Statesville, North Carolina
Balancing Criteria
Reduction of M!TN Through Short-Term Effectiveness Implementability Treatment
TeehnieaUEngineering Estimated Time for
Considerations Implementation
(years)
No reduction of MfTN is Level D protecllve equipment None <\ rE;alized. is required during sampling.
Reduction of mobility through Level C and D protective Treatability testing required. ,
treatment is reaUzed. Volume equipment required dunng site Available space could be a may increase activities. Excavating and problem depending on the grading may result in potential type of process implemented. release of dust. Noise TCLP criteria would need to
nuisance from use of heavy be met prior to disposal. Deep equipment excavations may require
dewatering and use of
sheeting/shoring.
Rooucllon of mobility through Level C and D protective Treatability testing required. ,
treatment is realized. Volume equipment required during SIie Available space c.ould be a may increase. activities. Excavating and problem depending on the
grading may result in potential type of process implemented.
release of dust. Noise TCLP criteria would need to
nuisance tram use of heavy be met prior to disposal. Deep equipment. Treated waste excavations may require
would be transported over dewatering and use of
public roads to the ottsite sheeting/sharing. Treated
disposal facility. material must meet the Waste
Acceptance Criteria of the
disposal facility.
---
Cost
Approx. Total Present
Worth •
$78,000
$2 million
$2.2 million
•
-----
Table 6-1
Comparative Analysis of Soil Alternatives
Sigmons Septic Tank Site
Statesville, North Carolina
Remedial
Alternative
Overall Protection of
Human Health and
the Environment
1 -No Action 0
2 -Excavation, 5
Onsite Treatment
with Solidification/
Stabilization and
Onsite Disposal
3 --Excavation, 5
Onsite Treatment
with Solidification/
Stabilization and
Offsite Disposal in
Subtitle D Landfill
--------------
Criteria Rating Approximate
Present Worth($) Compliance Long-Term Reduction of MJTN Short-Term Implementability withARARs Effectiveness and Through Treatment Effectiveness
Permanence
0 0 0 5 5 $78,000 • 4 3 3 4 3 $2 million
5 5 3 3 4 $2.2 million
A ranking of "O" indicates noncompliance, while a ranking of "5" indicates complete compliance.
•
I
Alternative I --No Action !'RESENT WORTH COST
I Discount Rate: 7% Site Name: Sigmons Septic Taiik Sile
Site Loc:ition: S1a1csville, North Carolina
I I I QU.-\:--'TITY I UNIT PRICE I TOTAL COST ITEM DESCRIPT!O:-J UNITS DOI.LARS DOLLARS
:S.:o Action (5-Year Review) so
I Sllbtotal -Caoital Cost $0
Contr.tctor Fee ( IO¾ ofCanital Cost) so
I LcL:al Fees. Licenses & Pcm1its (5% of Capital Cost) so
Em1inecrin11. & ,\Jministrativc ( 15% ofC:1nital C,,st) so
Subtotal so I Contiuucncv (25% ofSuhtot.il) so
TOTAL CONSTRUCTION COST '°
I PRESENT WORT! I O&M COST $78 424
TOTAL PRESENT WORTH COST $78,424
I Alternative I •· No Action OPERATION & MAJNTENA:-.:CE COSTS
Discount Rate: 7%
I Site Name: Sigmons Scptic Tank Site
Sitc Location: S1atesvillc, North Carolina
UNITS QUA:-JTITY UNIT PRICE TOTAL ANNUAL OPERATION PRESENT ITEM DESCRIPTION DOLLARS COST, DOLLARS T!ME, YEARS WORTH I 5. YEAR REVIEWS
Pcrso11nel (2·man crew@ 2 12-hour days) hours 48 $50 5480 JO SS,9S6 Supplies/ Trnvcl days 3 $3,000 $1,800 30 $22,336
I
Soil/Groundwater Sampling unJ Lab T csting sample 20 $S00 $2,000 30 $24,818 ReDort Prenarntion lump sum I SS,000 Sl,000 6 $,f,767
O&M SUUTOT AL $5,280 SS7.877
I Contractor Fee r 10% ofO&M ~ost) $528 t5.7S8
LC'll.al Fees, Licenses & Permits (5% ofO&M Cusl) S26 $289
CONT!NGENCY 125% of Subtotal) $1,320 S14,469
SUBTOTAL $6,600 S78.42•1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
I
Allrrn11tive 2 -E1c11v11tion, O,uile TrN1tment ,,./ Solidificatinn/Stnbliz:ition, PRESE,','T WORTH COST anJ O,uitt Di,pos11J
Discount Rate: 7%
S,te Same Sigmons Scptii; Tank S,1e
Site Location: S1.ucsvillc, North Carolina
L'l\'IT PRICE TOTAL COST ITEM DESCIUPflO,'I UNITS 0\JAJ\JITY DOLL\RS DOLLARS
1'>10BILIZATl01','/DEMOBJUZ,\TJON
Tr.inspnrt Equipment & Staff ,~h I SI00,000 SI00,000 Temporary Fac,litie~ each I S7S,OOO S75,000
EXCAVATION
Suil 1:xcavution -Contaminated Soil " 9,000 SIO $90,000 Excavate Onsile Dispos;il Arca " 9,!00 SIO $91,000 Excavation Confirm.nion Tc~ting (I li;,st per 100 ti) ,~, 1,089 SIOO $108,900 Dus1 Control & Ai, Monitoring '~ 18,lOO SIO $181,000 U.1d,fill E.,cavated Areas with Clean Fillfrrcuted Soil ,y 18,100 " $90,500 Plac.: l foot thick layer clc:an fill over dispos.il s,tc cy 2,200 SIO S22,000 !'lace 6 inchtop soil layer over excavated ,m:.u " 2,800 S20 $56.000 Gradin1,1 & Compuctin1,1 ucrc )5 55,000 $17,500 Seed & M1.1kh ~" Jj $2,000 $7,000
ONSJTE TREATMENT
Trcawbility Study lump sum I $50,000 $50,000 Solidilication/Stabil iz .. uion '" 2,925 $JO $87,750
EQUIPMENT & MATERIALS
Health & Safety Equipment each I 5100,000 SI00,000
Subtotal -Cunital Cost $1,076,650
Contractor Fee ( 1 O"/o ofCar,i!al Cost) $107 665
Le11.al Fees, Licenses & Permits (5% of Capital Cost) $53,833
En •inecrinu & Adminis1ra1ivc () 5% of Callital Cost) 5161.498
Subtotal
$1,399,645
Contln~cncy (25% nfSubt<Hal) $349,911
TOTAL CONSTRUCTION COST $1,749,556
PRESENT WORTH O&M COST $268,0J5
TOT AL PRESENT WORT! I COST S2,017592
Alteinativc 2 --E.,ca"mion, Ons,te Treatment w/ S,ilidification/Stabli.zation, OPERATIQ:,,; & ,\IAJ;,.,'TENANCE COSTS and Onsite Disposal
Discount Rate 7% Site N,l!Tle: Sigrnons Septic Tank Site
Site Loca1i,m: Statesville, }forth Carolina
UNIT PRICE TOTAL A:>:;-.;UAL !TE,\I DESCRIPTJQ:,,: U;-..'JTS QUANTITY DOLLARS COST, OOLLARS
Remedy \1onitnring & Five Y car Review/Report yc;1r I $5,280 $5,280
Soil Cap and L.iwri \binteriance m,mth " $!,COO S l ::,000
SUBTOTAL
$17,230
COJ\T[:-,;GE:>:CY (25% ofSubi.11Jl) $4J;:O
TOTAL
)2'1,600
Trc.ilability study and ~olidificatio11/at.iliili1.i1ion treltment costs arc from EPA gu1dan~c. ,,cndor·supplicd Lnform~lion, .uid ,im!lar lypc work J! other \ites 1 cy-1.J ton~
Costs assume :i !-year 1rea1ment time fr.irne,
Assumo:5 J S¾incrcuse in volume of so'1l treated via solidirlc,:irion/stab1li,mion
Transportariun ;,,nd disposal costs developed from R S Means 1999
O?ERAT!ON
Tl.\!£:. YEARS
JO
JO
PRESF.;-..T
-WORTH
$65,520
Sl-18,908
S214.428
$53,607
.~::,;s.o:,5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
.-\lcrrnutivc J -Licavatii:in, On site Trntrnent w/ Solidificalion/Stabli~ution, PRESENT WORTH COST ,md Omitr Dispo.,tl
Discount Rate: 7~'.
Site Name. Sigmon~ Septic Tank.s Site
Site Location: S1a1csville, :,.,;orth Carnlina
UNIT PRICE TOTAL COST ITEM DESCK!l'T!O!\' U:-llTS QUAi",'TJW DOLLARS DOLLARS
MOB !LIZ,\ TJOS/OE.\1O8 ILIZATION
Transpmt Equipment & S1a/f each I $100,000 Sl00,000 Temporary Facibtie11 each I S75,000 S75,000
EXCAVATION
Soil facavatiun -Contaminated Soil cy 9,000 $10 $90,000 Excavation Confirmation Testinl! ( I l<:st per l 00 fl:} test l.08'l SIOO $108,900 Dust Control & Air :Vlomtonn11 ,y 9,000 S!O S'l0,000 Backfill Exc.iv.itcd Area5 with Clean F,IJ cy 9,000 " $45,000 Place 6 inchtop soil byer over e~cavated areas cy 1,700 s::.o SH,000 Gradin11 & Cumpacunll ,ICfC " $5,000 S 12.500 SecJ & Mulch acre 2.S $2,000 $5,000
ONSITE TRE,\TMENT
Trcatability Study lump sum I $50,000 $50,000 S,,liJ ification/Stabi lization '°' 2,925 $30 $S7,750
OFFSITE DISPOSAL
Truck Transport '°' 1 l,846 "' Sl77,6<)4 Disposal at Subtitle D Landfill '°' 11,846 SJO $355,388
EQUU'1"1.ENT & MATERIALS
Health & Safety Equipment each I $100,000 $100,000
Subtotal -Caoi1al Cost Si 331,23 !
Contractor fee (J0"/4 ofCaoital Co.\ll $133.12)
Lcual Fees Licenses & Permit5 (5% ofC:a"ital CoM\ $66,562
Emtincerin11. & AJrniniwative /IS"/4 ofCaoital Cost) $199,685
Subtotal
$1,730,601
Con11n~cncv /25¼ of Subtlltal) $432.650
TOTAL CONSTRUCTION COST $2163251
PRESENT WORTH O&M COST $26,243
TOT AL PRESENT WORTH COST $2,189 494
Alternative 3 --Exc.1,·ation, Onsitc Treatment w/ SoliJiiica1ion/StJblization, OPERATION & :..lAL",JEN,\..\;CE COSTS anJ Offsite Disp(lsal
Discount R.ite 7%
Site Name: Sigmoru; Septic T.inks Sile
Site Location States,ille, North Carolina
UNIT PRICE TOTAL ANNUAL ITE.\1 l)ESt.RlPTION u:,,,·rrs QUANTITY DOLLARS COST. DOLLARS
:,.1,.m,1oring & ,\.lc:iintenance ofRc-Vcgcta1~J Are.1 Quart~rly ' $2,000 $8,000
SUBTOTAL
iiS,000
CONTl:-.:GF.i\"CY (:5% ,1fSuhtotaJl $'.l.,000
TOTAL
$10,0IIO
Tre,1\·ab'il"ny study ·,ind ~olid1!ic.1tion/.stabilitation treatment costs arc from EPA guidance, v~ndor-supplied information, and s.imilar type work at 01hcr sites 1 cy • ].) tons
Costs assume .1 I-year treatment time frame
Assumes,, 5%increase in \'olumc of soil lrcJteJ via solidific:itionhtabili:t.Jtion
Tran.~port.11ion ~nd dispos,il cos1s devdop~d from R.S Means !99<l
OPERATION
TIME. YEARS
J
PRESE:\'T
\\'ORTH
Sl0,<l<l5
$'.l.0.')'15
S5.'.l.N
S'.l.6.243
Sep-01-05 10:22am from-North .fund [phone]. T-318 P.002/003 F-466
UNITED s· 'ATES ENVIRONMENTAL PROTECTION AGENCY
RC:GION 4
l1TLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
1,eptember 1, 2005
Mr. Nile Testerman
North Cacolina Depa :tment of
Envirorunent and Na :;ura:,. Resources
401 oterlin Road, s,ite 150
Raleigh, North Caro.ina 27605
Dear i~:r. Testerman:
SUBJ: F'<eview of Re1,1ediccl Investigation for the Sigmon' Septic
Tank Site
Enclosed is a J emec.ial investigation report for the Sigmon' s
Septic Ta.nk Site lo ,ate,,. in Statesville, North Carolina. Please
revie"· the report submitted on August 30, 2005, and provide
comments to me by S,pterr,ber 21, 2005. If you are unable to meet
this timeframe, ple, se inform me as to when you will be able to get
your comments to me. Tl::.ank you for your cooperation.
If you have an, que,;:tions regarding this site, please contact
me at (4)4)562-8816.
Sincerely,
~~J~
Beverly T. Stepter
Enclo:::ur-3
lntemet Address {URL) • http://www.epa.gov
Hocyr::l1i1el/Roeyr::l3,blv • P n!ed wllh \/agiJtablo Oil B:liOCl Inks on RecyCIM Papor (Minimum 30% Pos1consumer}
• •
Draft Site Visit Minutes: Sigmons Septic Tank Site
FOR OFFICIAL USE ONLY
Attendees:
Beverly Stepter, EPA
Dave Jenkins, EPA
Nile Testerman, NCDENR
Andrew Grimmke, Black & Veatch
John Blanchard, Black & Veatch
Location: Sigmons Septic Tank Site
Date of Visit: June 27, 2005
June 30, 2005
Purpose: The purpose of this meeting was: 1) Hydrogeologists to "walk the site" and adjacent streams,
collect and analyze field screening samples for VOCs. 2) Provide update on progress and results of soils
operable unit RI, latest potable water sampling, and 3) Overall approaches for determining the extent of
groundwater contamination
Minutes:
1. As a recap, the groundwater and soils are being addressed under separate operable units; the soils
investigation has been completed and Black & Veatch is currently preparing the draft RI/FS. The soil
remediation will be straightforward. However, due to the complex hydrogeology at the site {fractured
bedrock, location of the site on a topographic ridge), delineating the groundwater contamination will take
more time.
Separating the soil and groundwater into separate operable units will enable the EPA to remediate the soils
more quickly. This has several benefits: a) Remediating the soils will likely remove (or contain) the source
of the groundwater contamination. b) The local community will see that progress is being made in
remediating the site.
2. Andrew and Dave walked up the northern stream from the vicinity of the Catawba River
(approximately1/4 mile from the River) towards the Site. The purpose of this activity was to become more
familiar with the hydrogeologic conditions at the site and to collect screening samples for voes. The overall
goal of the screening sampling was to determine where the groundwater was re-emerging as surface water,
and to determine if groundwater was contaminated with site-related contaminants at that location. This
activity would greatly assist in determining if/where to conduct more extensive groundwater investigation
activities.
The streams were flowing heavily due to recent rains. It was difficult if not impossible to determine if the
water in the streams was due to the rain or due to recharge from the groundwater. Andrew and Dave
collected screening samples from the streams and evaluated them using the ColorTec field screening
methods; there were no "hits."
In addition, they located a dry spot along the stream and excavated to a depth of approximately one foot
below the streambed. The rationale for that activity was that any water encountered below the stream bed
would be groundwater. The subsurface soil below the streambed was dry.
3. Based on the screening sampling issues in (2) above, Black & Veatch will return to the site and collect
-1-
• •
June 30, 2005
Draft Site Visit Minutes: Sigmons Septic Tank Site
FOR OFFICIAL USE ONLY
push point screening samples in the streambed during the dry season; preferably after a dry period of 2-3
weeks.
4. There has been some tree removal activity behind the Davidson property. John will determine the
purpose for these activities. If they are being conducted for new residential/commercial development, then
we will need to set up institutional controls, or at least a monitoring plan.
5. John distributed the results of the April 2005 potable well sampling event. They vary significantly in some
cases from the 2004 potable well sampling. The 2005 results have not been included in the RI per our
agreement with the EPA (results came after the risk assessment was underway). Of particular note were
several new wells added to the sampling network, the reduction in lead concentrations in some wells, and
the detection of Vinyl Chloride in SS-PW-03 (not used as potable water).
6. The site investigations will continue under separate operable units for soil and groundwater. The risk
assessment for the soil RI includes groundwater (we know the "nature" of the groundwater contamination);
however, we may need more work to delineate the groundwater contaminant plume (we don't know the
"extent."). If this next push point screening sampling event doesn't provide any more information regarding
the extent of groundwater contamination, then a decision will be made regarding whether or not to continue
to pursue active groundwater investigations or to limit future groundwater work to routine sampling of
existing wells.
7. The risk assessment results show that the surface soils over the site and the subsurface soils in the
lagoon need to be addressed. Potential remedies include: excavation/oftsite disposal of the lagoon soils
and the top 6 inches over the entire site; capping and installing a slurry wall around the contaminated soils
in the lagoon area while excavating/disposing oftsite of the top 6 inches of soil over the entire site; and
evaluating in-situ treatment options. Removing/capping/treating, etc. of the lagoon soils may resolve the
groundwater issues, as the lagoon soils are considered to be the "source." The monitoring and potable wells
would be monitored on a semi-annual or annual basis.
-2-
• • U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4, SCIENCE and ECOSYSTEM SUPPORT DIVISION
ATHENS, GA 30605-2720
4SESD-EIB
MEMORANDUM
NOV O 1 2002
SUBJECT:
FROM:
TO:
SESD EIB-ES Trip Report for the Well Installation and Field Sampling
Sigmon's Septic Tank Site, Statesville, NC;
EPA ID N_o. NCO 062 555 792;
SESD Project No. 03-0069
S. E. Matthews, P.O. [jc>f\ /v
Enforcement Section '\'\O
Enforcement Investigation Branch \
Giezelle Bennett
North Site Management Branch
Waste Management Division
. ' ' I ! ' NOY 1 2 2002
[•' L. \
The following is the SESD EIB trip report for the subject facility. If you have any
questions about the report, please contact me at [phone] or at email matthews.sharon
@epa.gov.
\.-'1: :_ ..
, L ..•. ) l
i
• • SIGMON'S SEPTIC TANK SITE TRIP REPORT
ST ATES VILLE, NORTH CAROLINA
SESD PROJECT NO. 03-0069
INTRODUCTION
During the weeks of October 7-IO, 2002 and October 21-24, 2002, a field overview of
well installation and field sampling activities was performed by USEPA Science and Ecosystem
Division (SESD) Enforcement Investigation Branch (EIB) personnel. The following persons
were present during all or some of the field activities:
Sharon Matthews USEPA-SESD-EIB [phone]
Brooke Fait Black & Veatch [phone]
Chris Allen Black & Veatch [phone]
John Blanchard Black & Veatch [phone]
Mike Sturdevant Miller Drilling Co. [phone]
Ron Gerrish Miller Drilling Co. [phone]
John Gorman Miller Drilling Co. [phone]
Troy Gradwell Miller Drilling Co. [phone]
As part of the well installation activities, four monitoring wells were installed to further
determine the extent of ground water contamination for this site. Soil, sediment, surface water
and potable water samples were also collected as part of the investigation. Samples were to be
analyzed for volatile and extractable organic compounds, metals, pesticides and PCBs. Five soil
and one water sample were selected to also be analyzed for dioxins.
SUMMARY
Black & Veatch and Miller Drilling Company personnel answered questions and
conducted well installation, well purging and sample handling techniques in a knowledgeable
and competent manner. The ground water monitoring wells installed as part of the RUFS were
constructed as per the field sampling plan. Ground water, potable water, soil, surface water and
sediment samples were collected as per the field sampling plan. Field work was conducted as per
the Health and Safety Plan developed for this site. It was recommended that water samples be
preserved and placed on ice as soon as possible after sample collection. It was also suggested
that the VOC samples be pre-preserved by the lab, rather than preserving them in the field. A
copy of the field overview checklist is included as Appendix A.
SITE BACKGROUND
Sigmon's Septic Tank Site is located at 1268 Eufola Road about 5 miles south_west of
Statesville, Iredell County, North Carolina (Figure I). The site is about 15 acres in size and is
divided into two properties. The southern parcel is almost 9 acres and is listed in the name of the
deceased Henry Sigmon, and the northern parcel is about 6.5 acres and is owned by Mary
Sigmon, the daughter. An office for Sigmon Environmental, Inc. (the current name of the
business) is located on the property.
1
• • The site includes aboveground storage tanks containing liquid wastes, with the source of
the wastes as unknown. There is also a waste pile and former lagoons onsite. The business
pumped septic tank wastes and heavy sludges from residential, commercial and industrial
customers, installed and repaired septic tanks and provided a variety of industrial waste removal
services. Possible sources of septic waste include Barnhardt, Clark Equipment, Union Glass,
Zimmer Industries (a medical supply company) and the metal treating business, Ro-Mac
Company.
From 1970 to 1978, the wastewaters were discharged to the City of Statesville sewer.
About 1973 or 1974, the service received permits and land applied sludges to area farmlands.
The process of land management appears to have continued until at least 1989, according to
septage management applications filed by the business. The file information did not specify on
which properties the sludges were applied and if the farmlands produced food crops.
About 1978-79, lagoons were dug at the site and received septic wastes:-No permits __
were issued for the lagoons. The business ceased operations in September 1995 for financial
reasons. Soon after, Mary Sigmon started Sigmon Environmental, which is the current operator
of septic services at the site. That business has been permitted to discharge to Irwin Creek
Wastewater Treatment Plant and McAlpine Creek Wastewater Treatment Plant since late 1995.
The site was investigated in June 1980 by the North Carolina Department of Human
Services for septage disposal problems. Nine wells were installed in the vicinity of the lagoons
that were sampled and analyzed for a variety of constituents. In November 1980, Sigmon Septic
Tank Service submitted an interim status hazardous waste permit application (USEPA Part A)
indicating that the site was used for disposal of hazardous waste. Mary Sigmon rescinded the
permit application as a generator and requested that the facility be reclassified as a transporter of
hazardous waste.
In 1985-86, two of the lagoons were apparently closed out. Four additional wells were
installed along the western edge of the lagoons and south of a storage shed on the property.
Analytical results indicated elevated levels of several metals, including barium, chromium, lead
and mercury.
Since 1989, Sigmon's Septic Tank Service has submitted applications and received
permits from the North Carolina Septage Management Program to operate a Septage
Management Firm and a Septage Disposal Site. The permit states that pumpings may only be
discharged at specified wastewater treatment plants.
The monitoring wells onsite have been sampled a number of times since their installation.
Metals and organic compounds have been detected in many of the ground water samples. The
North Carolina Division of Environmental Management and Division of Solid Waste
Management have issued at least three Notices of Violations regarding the ground water
contaminant levels in the onsite monitoring wells and some nearby private wells. Samples
collected from the lagoons in 1992 also indicated elevated levels of metals and organic
compounds.
2
• • In September 1993, the facility hired an environmental firm to sample and characterize
the sludges in the lagoons to comply with a closure request by the North Carolina Department of
Environmental Management. Results indicated elevated levels of total petroleum hydrocarbons,
metals and several organic compounds. The lagoons were closed by May 1995, by excavating
the sludges and mixing with sawdust and soil excavated from the northern portion of the site.
In December 1995, the site was referred to the North Carolina Superfund Section for a
possible emergency removal action. In January 1997, the site was referred to the USEPA Region
4 Emergency Response and Removal Branch for a removal evaluation. In April, USEPA
responded that the site did not meet the criteria for such a removal. In 1998, the North Carolina
Superfund Section conducted a Preliminary Assessment/Site Inspection (PA/SI) for the site
which included ground water, soil, surface water and sediment samples. The PA/SI confim1ed
that organic and inorganic compounds were elevated in the ground water, soils and surface water.
In March 2000, an ExpandeirSite Inspection (ES!) was completed by the North Carolina
Superfund Section and included ground water, soil, surface water and sediment sampling.
Several organic and inorganic constituents were detected in all media sampled at concentrations
above the background levels or exceeding the sample quantification limits.
As a result of that and previous investigations, it was proposed to conduct a Remedial
Investigation/Feasibility Study (RI/FS) on behalf of USEPA Region 4 to gather data to further
define the nature and extent of contamination at the site and to develop a Record of Decision
(ROD). Site activities were to include the installation of seven additional wells to monitor the
shallow, intem1ediate and deeper water bearing zones, install seven borings to profile and sample
the soils at depth, and to collect ground water, private drinking water, surface water and sediment
samples for volatile and semi-volatile organic compounds, pesticides/PCBs, dioxins and metals.
This field work was to be conducted during October 2002.
Monitor Well Drilling and Sampling Activities
Background well MW-JOA was installed as the first well, beginning on October 9. The
well was drilled with hollow stem auger to refusal, which was about 31 feet below land surface
(bis). Air rotary was then used to drill to about 68 feet bis. The well was allowed to stand
overnight to detem1ine if any of the fractures noted during drilling would produce enough water
for sampling. The next morning, there was about 15 feet of water in the well. The well was
completed with a 2-inch 0.010 slot stainless steel screen set from 55 to 65 feet bis and 2-inch
Type 304 stainless steel threaded well casing. The filter pack, bentonite seal and grout were
placed as per the field sampling plan specifications.
Monitoring well 12B was drilled to about 68 feet bis and screened from 55 to 65 feet bis.
Monitoring well 13B was drilled to 83 feet bis and screened from 72 to 82 feet bis. Monitoring
well I IC was drilled to 68 feet bis and screened from 55 to 65 feet bis. All wells were
completed with the same well installation techniques and procedures as well MW 10 A. These
wells were all developed, purged and sampled according to the field sampling plan prepared for
this site. The wells were developed by pumping a minimum of three to five well volumes. Split
spoon samples were also collected for lithologic descriptions.
3
• •
For the sampling episode, the four monitoring wells were purged for a minimum of three
well volumes and until the field parameters for pH, temperature, specific conductivity, turbidity,
DO and ORP had stabilized. Samples for metals, extractable organic compounds, PCBs and
pesticides were collected with a Grundfos Redi-Flo pump. Samples for volatile organic
compounds were collected with a disposable Teflon bailer lowered into the well on Teflon coated
wire. Samples were collected directly into the appropriate sample containers. VOC vials had
been pre-preserved prior to sample collection with 4 to 6 drops of HCL. Metals samples were
preserved after sample collection to a pH of less than 2 with nitric acid. The pH was checked
with pH paper to insure enough acid had been added to achieve the required pH.
Monitoring wells MW I IA, MW l lB or MW 12A could not be installed due to lack of
water at shallow depths. It should be noted that at the time of the field work, the area around
Statesville, NC had been experiencing the worst drought in recent history and had enacted
serious water restrictions due to lack of precipitation.
Potable Well Sampling
Nine potable water wells were also sampled as part of this RI/FS. These wells were
purged at least I 5 minutes, allowing ample time for the in-situ pumps to cycle on and off. Purge
water was drained away from the well via a garden hose to prevent pooling around the well. The
well samples were collected at the pump head spigot and were to be analyzed for volatile and
extractable organic compounds, metals, PCBs/pesticides. Samples were collected directly into
the appropriate sample containers. VOC vials had been pre-preserved prior to sample collection
with 4 to 6 drops of HCL. Metals samples were preserved after sample collection lo a pH of less
than 2 with nitric acid. The pH was checked with pH paper to insure enough acid had been
added to achieve the required pH.
Surface Water/Sediment Sampling
Eight surface water and eight sediment samples were collected as part of the Rl/FS.
Surface water samples were collected prior to the sediment samples directly into the appropriate
sample containers. VOC vials had been pre-preserved prior to sample collection and metals
samples were 'preserved after sample collection to a pH of less than 2. VOC sediment samples
were collected with the stainless steelffeflon Encore sampler. All other samples were collected
into a decontaminated stainless steel bowl and mixed with a decontaminated stainless steel spoon
prior to placing the sample into the appropriate sample containers.
Soil Borings
The deeper soil borings were collected by using the hollow stem auger/split spoon
method. Depths of each boring varied, due to auger refusal. The sampling intervals were
usually Oto 2 inches bis, 2 to 4 feet bis, 5 to 7 feet bis and 10 to 12 feet ft bis. It had been
proposed to drill boring SF/SB-06 to a depth of 32 feet, but competent rock prevented the hollow
stem auger to go below 12 feet bis. Proposed borings SF/SB-10 and SF/SB-I I could not be
collected at all due to drill rig inaccessibility. SF/SB-13 was substituted in their place. Some of
the samples had a noticeable odor of septage and sometimes an oily/sludge layer.
4
• •
The ten shallower soil samples (0 to I foot bis) were collected with decontaminated hand
augers. VOC soil samples were collected with the stainless steelffeflon Encore sampler. All
other samples were collected into a decontaminated stainless steel bowl and mixed with a
decontaminated stainless steel spoon prior to placing the sample into the appropriate sample
containers. All deep and shallow boring samples were to be analyzed for volatile and extractable
organic compounds, metals, pesticides and PCBs. Five of the soil samples were also to be
analyzed for dioxins.
Final Sample Totals
A total of 40 soil and 12 water samples were sent to the Sentinel CLP laboratory for
inorganic analyses. A total of 14 soil samples were sent to Soil & Environmental Testing
Services for TOC and Grain Size Distribution analyses. Fourteen soil samples were sent to
Accura Analytical Laboratory for soil pH analysis.-A total of 40 soil and 12 water samples were
sent to the Liberty CLP Organic laboratory for VOC, base neutrai-acid (extractable) organic
compound and pesticide/PCB analyses. The USEPA Region 4 SESD laboratory received 9 water
samples for inorganic analysis. Wright State University will receive 5 soil and I water sample
for dioxin analysis.
CONCLUSIONS/RECOMMENDATIONS
Black & Veatch and Miller Drilling Company personnel answered questions and
conducted well installation, well purging and sample handling techniques in a knowledgeable
and competent manner. The ground water monitoring wells installed as part of the RI/FS were
constructed as per the field sampling plan. Ground water, private drinking water, soil, surface
water and sediment samples were collected as per the field sampling plan. Field work was
conducted as per the Health and Safety Plan developed for this site. It was recommended that
water samples be preserved and placed on ice as soon as possible after sample collection. It was
also suggested that the VOC samples be pre-preserved by the lab, rather than having to preserve
them in the field.
5
'VOIJIMAN, NC -------·--·· .......
t)OO' .. __ J
Ftf;l'l<I I >I IL \L\I'
<t, ;,\11_1,\''-.: ,',l•:l'Tlt f-\1\'h -IT\".· ST \'Iii::-\ ILi.i<:. •\'I.
• •
APPENDIX A
USEPA REGION 4 FIELD OVERVIEW CHECKLIST
SIGMON'S SEPTIC TANK SITE
STATESVILLE, NORTH CAROLINA
SESD PROJECT NO. 03-0069
•
EXHIBIT 2.1
REGION 4
•
HAZARDOUS WASTE FIELD OVERVJEW CHECKLIST
Facility/Site Name
Address C) 2. l,, 0
e...
EPAfDNo./0Gu Oi.:,Z SSS '7·"2..
5"(p,) -88 2-t/-
Affiliation PhoneNo. ')·lo 521-8\\3
Address
Sam !in Personnel
Other Personnel & Affiliation
T e of study?
Study Ian issued? '--e. ':::>
Study plan reviewed by the Division?
Comments:
Was study plan followed? L\ e, 7·
Comments: I
Was a safety plan prepared for the study?
Comments:
Was the safety plan adequate?
Comments:
Was the safety plan followed?
Comments:
¥D
Additional comments or infomiat.ion: ~ l
Checklist sections completed
for this overview:
Date issued?7 ° O ·-
--1-_,l..\ .
·/\-\--, Cc-y.._.,+c.._
Acceptable?
·,:lJ: V'"'-~e~i\~ i'. t,,d\ v\'\u'\i V\.\ ,c
'X 2Ci\ o< 4(X, r,J A
l. 3. 5.
Key: CD.General Procedures ~Surface Water Sampling
. Ground Water Sampling 5. Waste Sampling
., Soil, Sediment, Slud e Sam !in (i[;Mon.itorin Well Installation
D(
6.
0-\:,\:h b<,~
.:'.)\<_,h\'I e.c..
"3ic,\ r\~bl::acc\
2 -34 (* Revisions March 2001)
• •
SECTION I -GENERAL PROCEDURES -SAFETY, RECORDS, OA/OC. CUSTODY. ETC.
I. Type samples collected? .,,,, ,; 'i)J~ Vr: U11) <"·On/,. I••· ·00. Comments: Ood 60 ~I 2 ), al , I I I I I J
2. Were sampling location~oSrly selected?
Comments: .
3. Were sampling locations adequately documented in a bound field log book using indelible ink?
Comments: 1..-\L:;,
V
4. Were photos taken and a photolog maintained? 'f7 Comments:
5. What field instruments were used during this study? fu'( '('('-. on~ --\--u--v ~ ~ )
· Comments:
.
6. Were field instruments properly calibrated and calibrations recorded in a bound field log
book?_. '-Y--S
Comments:
7. Was sampling equipment properly wrapped and protected from possible contamination
prior to sample collection? rs Comments:
8. Was sampling equipment constructed of Teflon®, glass,~
Comments:
9. Were samples collected in proper order? (least suspected contamination to most contaminated?)
Comments: '--\f. s .
10. Were clean disposable latex or vinyl gloves worn during sampling? ~,lS,
Comments:
11. Were gloves changed for each sample station? f-5
Comments:
12. Was any equipment field cleaned? 1.'f S
Comments:
13. Type of equipment cleaned: 'b,w\ ':,, ?f'-', Y\. ':, ) --h-~,, I w L-; J\-J._; C<~+w"
Comments: G,. , L J e,,., C -r ,;--,n?_ \ ~. , .• ,[; ( • if /Ir ,r;r. , ) J
14. Were proper field cleaning procedures used? ½l S
Comments:
15. Were equipment rinse blanks collected after field cleaning? ~
Comments:
l 6. Were proper sample containers used for samples? rs ~ ~ Comments: Y' l "\ -l""-"---1-.J. '-> K 1, 7
EISOPQAM 2 -35 (* Revisions March 2001)
17.
18.
19.
20.
21
22.
23.
24.
25.
26.
• •
Were split samples offered to the facility owner or his representative?
Comments: A) ,4--
Was a Receipt for Samples fom1 given to facility representative? 4 Comments: )_),
Were any duplicate samples collected?
Comments:
Were samples properly field preserved? \[bl\ · i:-lC{,
Comments: ~'> -,, (-t~<c
Were field and/or trip blanks utilized?
Comments:
Were samples adequately identified with labels or tags? \,7vb,,d) 1M, ~
Comments: 1"l>{h,,, ':> -rr:: u: i,.,
Were samples sealed with custody seals after collection'/ t:11 ';,
Comments:
What security measures _were taken to insure custody o~ the samples after collection?
Comments: 1-., .,nt-1 r, I/ ; .P, 0 '"' lo c../c_Q J .
Were chain-of-custody and receipt for samples fonns properly completed? (,f S
Comments: ~ n1 '--( .l TE:--rr=--
27. Were any samples shipped to a laboratory'/ ~7
Comments:
28.
29.
30.
31
Jfyes to No. 27, were samples properly packed? Y,"7
Comments:
Tf shipped to a CLP lab, were Traffic Report Forms properly completed?
Comments: I ,.,c_ ,--+,, , ,I -rv ;,L \.',·L '1 (: J
• I)
What safety monitoring equipment, protection, and procedures were used prior to and during
sampling? \VA -[OcO '\: q,,-W) U~I\) s¾,,(a Le.. Comments: ' O
\Vas safety monitoring equipment properly calibrated and calibrations recorded in a bound field log book? '-'ll ';,
Comments: 6
EISOPQAM 2 -36 (* Revisions March 2001)
• • SECTION 2 -SAMPLING -GROUND WATER
l. Type of wells sampled?(~ ~industrial,etc.)
Comments:
2. Were wells locked and protected?
Comments:
f,,v ,,,,.v-w:_1--,r<·, I'-) CL>t ll:,,
3. Were identification marks and measurement points affixed to thewells? >"\;;·,~ c.. -• •.W
--;--,.._ \
\_'u_;
Comments: . .1,t l '::> ,_,..-\"\~ ,.__, ~lA.., \ ,,-\ -<n--<:._ \\ a ,( I')\•.'\ u.:,--di ~
\
4. What were the sizes and construction materials of the well casings? h-{)\.10
Comments: ;} 1' 55t-C.~, I~ -,
5. Were the boreholes sealed with a concrete pad to prevent surface infiltrationl___
Comments: ht\ . ' --u ..l. ";,
"
6. Was there a dedicated pump in the well? Y\C
Comments:
7. Was clean plastic sheeting placed around the wells to prevent contamination of sampling
equipment and containers? ~s Comments:
8. Were total depths and depths to water determined before purging? ·-y..s,
Comments:
9. What device was used to determine depths? 'S-c\...crvu.S\--w L M'vvcL.✓
Comments:
10. Were measurements made to the nearest 0.01 ft?
Comments:
--y '>
11. Was the measuring device properly cleaned between wells? y·>
Comments:
12. Was the standing water volume in each well determined? ·--t ';J
Comments: .
13. How was the volume determined? \\) , u:)L,
Comments:
14. Was a sufficient volume purged prior to sampling? y-:,
Comments:
15. How many volumes? ~ 3 ~ V\. \ \'\\. ...;,.,V\ o-'\
Comments:
16. How was the purged volume measured'/ ~ ,iC\...t. d..<vtv'\
Comments:
I 7. What was the method of purging? E;'{ ,.h\ c\._-\u ':,
Comments:
EISOPQAM 2 -37 (* Revisions March 2001)
• •
18. Were pH, conductivity, temperature, and turbidity measurements taken and recorded at least
once during each well volume purged? '--'f5
Comments:
19. Were pH, conductivity, temperature, and turbidity readings stable prior to sampling? Ly>
Comments:
20. How many wells were sampled? Upgradient? Downgradient?
Comments: '\ y,. ,l ; VI "-' .. , i , . .( Y'r\lj
I 8 e 21. How were the samples collected? Other
Comments:
22. lf a pump was used, what type? ~{J'Y\G\~7
Comments:
23. [fa pump was used, was it properly cleaned.before and/or between wells? -y'?
Comments:
24. What were the cleaning procedures? ~-"-'()i \·•"\" :I'\~} Ii)\ I lrl\w-,_,;,._, \i,.Lll.
Comments:
25. Did hailers have Teflon® coated wire leaders to prevent rope from coming into contact with
water? '1'7
Comments:
26. Were hailers open or closed top? C\o'>< ~
Comments:
27. Was a clean bailer and new rope used at each well? '1' Comments'
28. Were samples properly transferred from the sampling device to the sample containers? (i.e.,
volatile sample first -not aerated, etc.) ''f-·'7
Comments:
29. Was pH of preserved samples checked to insure proper preservation? ')l7
Comments:
30. Were samples iced immediately after collection? 'i\O~ c~\~"\ 7
Comments:
31. For what analyses were the samples collected? "cl.'--;, r.,,cc, v~ '7 ' ~"'/rL-o''> Comments:
32. If samples were split, what were the sample/station numbers for these? fJA
Comments:
33. Are the ground water samples being filtered? I"'';)
Comments:
34. If the ground water are being filtered, what procedure is being used? tJP, Comments:
EISOPQAM 2 -38 (* Revi:-.ions March 2001)
• •
35. Is low flow/low volume sampling being conducted (e.g., is the intake of the pump at the middle
of the screen)? ~'\ ~ Comments:
36. Iflow flow/low volume sampling is being conducted, is the water level being measured
constantly to insure minimal drawdown of the less than 3 to 4 inches? ,_,Q
Comments:
33. Other comments or observations.
-
EISOPQAM 2 -39 (* Revisi()n:,; March 2001)
• • SECTION 3 -SAMPLING -SOIL, SEDIMENT, SLUDGE, ETC. (Non-containerized)
I. Type of samples collected'/ ;S_,-{ l xJ._.-~ I
Comments:
2. General description of samples? ~c) \---,o ;'.),,:-.__\
Comments:
3. How many samples were collected? e,:: sw c\ <, l l,.Q_ &_ b,,-,1,'\\/• a l-Z
Comments:· 8 = Seel hw"'-A ,, ·,., xfJ_--\0
4. Were background and/or control samples collected? \p o..d ~" J_ ~
Comments:
5. Were representative samples collected? Vo./ 2_
Comments: --
6. Were grab or composite samples collected? ~
Comments:
7. Were composite samples areal or vertical? }J ~\
Comments:
8. How many aliquots were taken for the composite sample? µ.A
Comments:
9. ')\-< l.-S"., S-0--l What procedures and equipment were used to collect samples? 1,<......,
Comments: ".) o-,-.A ,;,.-.... -,,, , . ) I t.-u,,v, _.(_,.--\IQ;\ L. D r.u .r , .,,-c,
I , a
10. Were samples thoroughly mixed prior to putting them into the sample containers?
Comments:
11. Were samples properly placed into sample containers? 't2 '.:;,
Comments:
12. Were sdmples iced immediately after collection? ·6""""'-~\')'\.( <.:, -no\-4~
I . ~..k ~ Comments: \ { . -.
I voe~ E.a:' > iAfliJ<i, 7R-1r/?CB 13. For what analyses were the samples collected?
Comments: ct, Ol!-;A
14. If samples were split, what were the sample/station numbers for these? I" j)
I Comments:
I ~ 1.'.,-':Ir o:i!\.. f:i,.., ,; .,_ I 15. Was a drilling rig, back hoe, etc. used to collect soil samples? I '.;>~ \.,,, Comments:
16. Were thb drilling rig(s), backhoe(s), etc., properly cleaned according to the SOP, Appendix B,
prior to ~rriving on site? i'< ', . I
Comments:
I
I 7. What was the condition of the drilling and sampling equipment when it arrived on site?
Commetits: ~ -l"i ,-,yo,V -u)r,/) -~or· ,] '11 ✓-,--h -.F-.1-
I \ I J I
EISOPQAM 2 -40 (* Revisions March 2001)
• •
18. Was a decontamination area located where the cleaning activities would not cross-contaminate
clean 'and/or drying equipment? V-..{? Comments:
19. Was clean equipment properly wrapped and stored in a clean area? r7
Comments:
20. Was the drilling rig(s) properly cleaned between well borings? ·~ j
Comments:
21. Were the cleaning and decontamination procedures conducted in accordance with the SOP?
Comments: , U '?
u
22. Other fOmments or observations:
--
EISOPQAM 2 -41 (* Revisions March 2001)
• • SECTION 4 -SAMPLING -SURF ACE WATER (Pond. Stream. River. Leachate, Etc )
L Type of samples collected? --p <.JY'\ <i
Comments:
2. General description of samples? j.\.,:) l-..---t') -tv'<b [U\
Comments:
3. How many samples were collected? £i :Ju1'i-u.. <JL 1.))1.J.-v..1'(
Comments: -
4. Were background and/or control samples collected? WO.; ~ V C'-). c!,.. \ C LC \,\...Q. L,t
Comments:
5. Were grab or composite samples collected? er~
Comments: .
6. How many aliquots were taken for t)le composite sample? µlt-
Comments:
7. What procedures and cluipment were used to collect the samples? 1c_ ow c.,\--ee,\
Comments: 11"<' J-t~ ·,,Cl -~ ~ I~ r ~. ,v--,f
_} ~
8. Were samples collected directly into sample containers? 'Y '.> Comments:
9. Did the sampler wade in the stream to collect tl1e samples? ¼.J VY\. \,cv-J<..
Comments:
10. Were ilie samples collected upstream from ilie sampler? ~":,
Comments:
11. Did the sampler insure that r[!iled sediments were not collected along with the water samples?
Comments: -1/'."7
12. Were representative samples collected?
Comments:
V'f ';>
13. Was the pH of preserved samples checked to insure proper preservation? ~y. ~
Comments:
14. Were samples ic~d inlmediately after collection? n~!--c...~::, i~Lck~
Comments:
15. For what analyses were the samples collected? "\Joe's eoc''.> ~ .,A I "\)Cu '.s I ,
Comments: •r,J.-\.:J.7
16. If samples were split, what were the sample/station numbers for these? µ!,;
Comments:
17. Other comments or observations: Wc-U...,-:5_, • ,\~L 1'¼-I-' I'\<.·•· • I· ,,.kl,_,
' .J
EISOPQAM 2 -42 (* Revisions March 2001)
• •
SECTION 6 MONITORJNG WELL INST ALLA TJON
GENERAL .
I. Were the wells installed in the proper locations in accordance with the study plan and/or project operations plan (POP)? ·y--1 Comments:
2. Were the wells installed starting in the least contaminated area and proceeding to the most contaminated area? \.\{ 'J Comments:
3. Were proper safety protocols employed during the well installations? Vf 7
Comments:
4. Were samples of the drilling mud, water, bentonite pellets, filter pack materials, etc., collected
for quality control analy.ses? v,.1,1\ L:,\.\J.c~:.:\-~e.\.,~ Q'iv;p,,~ (",v.X-hl<.c-,J..-,_,
Comments: ON"-\ lo\t~ W~ QLl.L,ol~ ... J EQUIPMENT DECONTAMINA TJON
5. Were the drilling rig(s), backhoe(s), etc., properly cleaned according to the SOP, Appendix B, prior to arriving on site? CULOnl"\i'.. c\ uY\ -':, ·, k Cl/) ~-'.) C, "? Comments:
6. What was the condition of the drilling and sampling equipment when it arrived on site?
Comments: -\t-~<"\...... c:, \-eo.'"' -O--n-, >fi. ,\ 10 I 110 '-
' ..
7. Was a decontamination area located where the cleaning activities would not cross-contaminate clean and/or drying equipment? \\t'::>
Comments:
8. Was clean equipment properly wrapped and stored in a clean area? i" ':,
Comments:
9. Was the drilling rig(s) properly cleaned between well borings? 1 '.:,
Comments: .
I 0. Were the cleaning and decontamination procedures conducted in accordance with the SOP?•i'<:S Comments:
II. What type of drilling method(s) was used to install the wells? V,o\\vw '.::,-\<'(Y) 0--0<:,f-,Y-
Comments: o...:.,< 'o-\-•c•y)
12. Was this drilling method(s) the same as proposed in the study plan and/or POP? '1°C:,
Comments:
13. Were soil samples collected for logging and analyses as the wells were installed?
Comments: "io \; \.-"'1 vN'0. \J,l-1 U :> ~ Q.-J Cl.<.< ro\--Cc<u \ I
'-\ ' I S' 14. If yes to 13, at what intervals and by what method? 0 ,z) 2--..l,-~ "-"-,.,,__,__j
Comments: '_,, "?'7
I
15. If air rotary was used, was an in-line organic air filter employed? \Vas a cyclone velocity dissipator used? ~e,5 Comments:
EISOPQAM 2 -45 (* Revisions March 2001)
• •
16. What diameter borehole(s) were installed? ,_,..,,,_,.,J.. .. <\'lz.;' \\) i\ 51'\
Comments: ·-..,. xJi ,.J i yec_ IA .::; \-c~ M.., -,, -., <.k,_, I .L '-" 3o<1
I I 7. Were surface outer casings used? 411
Comments:
18. lfyes to 17, what size and to what depth? J\.i BLS Comments:
19. Were the wells double cased? \'\0
Comments:
20. If yes to 19, explain procedure. IJ.A Comments:
PERMANENT WELL INSTALLATION
21. What type of well casing(s) and screen(s) were used? o/ I 1 :~n\-( :,'o, SD.-,.(
Comments: -:3' oh "-::, t)Y\ T'i re .3o 4 w/ ,0 1su~
' 22. What diameter were the well casing(s) d'' ) " Screen(s)? '
Comments:
23. Was there a mininmm two inch annulus around the casing between casing and borehole was or inside augers)? '¥';;, Comments:
24. What was the length of the well screen(s)? \0 '
Comments:
25. What was the slot size of the weHscreen(s)? 0,010 -; t"vC "
Comments:
26. Was the well screen(s) commercially manufactured? y' ';:, If so, by whom? ·3",, 1,-\. _.., '5 c"1A-
Comments: ·
27. Was the bottom of the well screen(s) plugged or capped? c,~cc\
Comments:
28. Were sand and/or gravel (filter) packs installed? rf >
Comments:
29. Specify type of materials in 28 [(play sand, Ottawa sand, etc.) and grain size (20/30, 20/40, etc.)], if known. 2.D/SO C:..hc k->' ::,c, ~,J 3c/1..t-; Comments:
30. Was a sieve analysis conducted to determine well screen slot size and filter pack grain size? Comments: \JU_ .. ~ ~: ':, \,_,,., : C c-5.: IH'-<. .r( J .., v 1 ,· n:,-\o ... \..\ •, ,_\ IV\ ~--Iv,--: f\<• "-"-l I l) J 31. Were the wells installed to the proper depths? 'y''.:>
Comments: "
32. Were well screens placed at the proper intervals? '--Ji '7
Comments:
33. Were the filter packs placed a minimum of two feet above the well screens'! L!L.>
Comments:
EISOPQAM 2 -46 (* Revisions March 2001)
• •
34. Was the tremie tube method used to place the filter packs? -\-c."""JJ
Comments: ·._0; I\ \ '"-" .. \ . .-po-~ · " --'---nr ~-J. {I a r, , :+ , ..-, \_! •
35. Were seals placed above the filter packs? 1> Comments: .
36. If yes to 35, what material was used for the seals'/ ~ ',J) c.ec:::L s -b.c.k~
Comments: ~L\.Q.. \-<;,
37. Was the vertical thickness of the seals a minimum of two feet? "r"<_;,
Comments:
38. Ifbentoni_te pellets were used for the seals above the filter packs, were they allowed to hydrate a
minimum of 8 hours? Co o....\e.,\ flk-\. \..\:.--\-<;, Comments:
39. Did contractor/driller have documentation from manufacturer stating recommended hydration
time? If> Comments:
40. Was the tremie tube method used to place the bentonite pellets? -N .. \'0U .~J
Comments:
41. Was the annulus grouted from the seal to within two feet of the ground surface, or below the
frost line? Uf? Comments:
42. Was the tremic tube method used to place the grout in the annulus? ·:-y~c....
Comments:
43. lfno to 42, what method was used? "'7'-'YV~ Comments:
44. What type of grout was used to seal the annulus (neat cement, cement/bentonite, cement/sand,
etc.)? V \) It. ~ul& ~r~\L ~v-0-\-Comments:
45. What grout mix ratio was used? (should be stated in the POP) IO yo--'"•c\ ':> \2" ✓ J ()..\.\ '-',,
Comments:
46. What was the density of the grout? (lb/gal, etc.) 10 7av,..,c:\s \2-'2-4 '1 C•-.\. \ 0 ·r,
Comments:
47. lfbentonite grout was used, was the density at least 9.4 lb/gal? fS> Comments:
48. Was the density determined using a mud balance? ""f 7 Comments:
49. Was the grout allowed to set a minimum of 24 hours before the surface pad was installed?
Comments:
50. Was a concrete surface pad installed with an outer protective casing and locking cap? ~y.::,,
Comments: r<\ u{'(' S ,,,.__, '7
I ~ /I
51. How far below the ground surface did the concrete pad extend? 3 f._ J(. (,_,
Comments: ~
EISOPQAM 2 -47 (* Revisions March 2001)
• •
52. What were the dimensions of the concrete pads? ?:/ X 3' .I( (. Ii
Comments:
53, Did the well casings extend to a minimum of 2.5 feet above the ground surface? .'vf 7 ,v-
Comments: ~
54. How far above the ground surface did the outer protective casings e>.1end? ,;) 1~ '
Comments:
55. Did the outer protective casings have weep holes? '(7 Comments:
56. Were the wells properly developed? r Comments:
57. Describe method of development. r-1~ ,"( ~\,LI'"~~
Comments: --
·58. Give a general evaluation of the activities observed during the installation of the wells.
Cominents .\:ol...\.u~ Sol?
TEMPORARY WELL INSTALLATION
59. Describe methods and procedures.
Comments:
.
EISOPQAM 2 -48 (* Revisions March 2001)
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
CERTIFIED MAIL
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
July 11, 2002
RETURN RECEIPT REQUESTED
Steven and Joyce Lambreth
1228 Eufola Road
Statesville, North Carolina-28677
SUBJ: Sigmon's Septic Tank Site
Statesville, NC
Dear Mr. and Mrs. Lambreth:
The United States Environmental Protection Agency (US EPA) pursuant to the
authority and requirements of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) 42 U.S.C. §9601 et seq .. (the 'Superfund'
Law) is currently conducting an investigation of the release of hazardous substances
from the above referenced site. As you may know, the North Carolina Department of
Environment and Natural Resources (NC DENR) has already conducted two (2)
investigations and now, the US EPA is planning a more extensive study to determine
the chemicals present in the soil, groundwater and surface water/sediment and their
location.
Therefore, iri order to conduct this study, the US EPA requests your cooperation
by providing access to your property on Eufola Road and Mustang Drive for the US
_ EPA's personnel, contractors, and representatives.
Please sign the enclosed access agreement and return it to the US EPA in the
self-addressed postage paid envelope no later than July 26, 2002. If you have any
questions, please give me a call at [phone].
Sincere!
~~
Enclosure
· zelle S. Bennett
Remedial Project Manager
Internet Address (URL) • http://www.epa.gov
Recycll!d/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper {Mlnimu,ll 30% Poslconsumer)
• •
ACCESS AGREEMENT
1. I, _________ , am the owner of the property located at __________ _
and as such I have the authority to sign this authorization.
2. I grant authorization to the United States Environmental Protection Agency (EPA}, its officers,
employees, contractors and other authorized representatives to enter the property located at __
_________ . This authorization allows EPA, its officers, employees, contractors and
other authorized representatives to have access to the property to conduct all actions necessary
to evaluate the nature and extent of contamination at the Sigmon's Septic Tank Site. EPA's
activities at the Site will include, but not be limited to, the following:
a. collect groundwater samples from drinking water wells and springs (if any);
b. collect soil samples;
c. clearing of debris, undergrowth, and small trees, as necessary, to ensure access to
sample locations;
d. transport equipment onto and about the Site as necessary to accomplish the above
activities.
3. The consent for access and use granted herein will commence on August 1, 2002 and will
continue until EPA completes the above activities.
4. I realize that these actions by EPA are undertaken pursuant to its response and enforcement
responsibilities under the Comprehensive Environmental Response, Compensation and Liability
Act (Superfund), 42 U.S.C. Section 9601 et seq., as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) (Public Law 99-499).
5. Every effort will be made by the EPA representative to minimize the impact of this work. Your
yard will be completely restored if any disturbance occurs. All work will be performed at the
expense of EPA.
6. Please return this signed and dated Access Authorization to:
Giezelle S. Bennett, Remedial Project Manager
Environmental Protection Agency, Region 4
Sam Nunn Atlanta Federal Center
61 ForsY1h Street
Atlanta, GA 30303
Name: ____________ _ Date: ---------
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
July 11, 2002
4WD-NSMB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Wade S. Lambreth
11 0 Lambreth Ridge Dr
Statesville, North Carolina 28677
SUBJ: Sigmon's Septic Tank Site
Statesville, NC
Dear Mr_ Lambreth:
The United States Environmental Protection Agency (US EPA) pursuant to the
authority and requirements of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) 42 U.S.C. §9601 et seq., (the 'Superfund'
Law) is currently conducting an investigation of the release of hazardous substances
from the above referenced site. As you may know, the North Carolina Department of
Environment and Natural Resources (NC DENR) has already conducted two (2)
investigations and now, the US EPA is planning a more extensive study to determine the
chemicals present in the soil, groundwater and surface water/sediment and their location.
Therefore, in order to conduct this study, the US EPA requests your cooperation
by providing access to your property for the US EPA's personnel, contractors, and
representatives.
Please sign the enclosed access agreement and return it to the US EPA in the
self-addressed postage paid envelope no later than July 26, 2002. If you have any
questions, please give me a call at [phone].
Enclosure
~,e, ~
·ezelle S. Bennett
Remedial Project Manager
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Prinled with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsumer)
I.
• •
ACCESS AGREEMENT
1. I, _________ , am the owner of the property located at __________ _
. and as such I have the authority to sign this authorization.
2. I grant authorization to the United States Environmental Protection Agency (EPA), its officers,
employees, contractors and other authorized representatives to enter the property located at __
_________ . This authorization allows EPA, its officers, employees, contractors and
other authorized representatives to have access to the property to conduct all actions necessary
to evaluate the nature and extent of contamination at the Sigmon's Septic Tank Site. EPA's
activities at the Site will include, but not be limited to, the following:
a. collect groundwater samples from drinking water wells and springs (if any);-
b. collect soil samples;
c. clearing of debris, undergrowth, and small trees, as necessary, to ensure access to
sample locations;
d. transport equipment onto and about the Site as necessary to accomplish the above
activities.
3. The consent for access and use granted herein will commence on August 1, 2002 and will
continue until EPA completes the above activities.
4. I realize that these actions by EPA are undertaken pursuant to its response and enforcement
responsibilities under the Comprehensive Environmental Response, Compensation and Liability
Act (Superfund), 42 U.S.C. Section 9601 et seg., as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) (Public Law 99-499).
5. Every effort will be made by the EPA representative to minimize the impact of this work. Your
yard will be completely restored if any disturbance occurs. All work will be performed at the
expense of EPA.
6. Please return this signed and dated Access Authorization to:
Giezelle S. Bennett, Remedial Project Manager
Environmental Protection Agency, Region 4
Sam Nunn Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
Name: ____________ _ Date: ________ _
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
CERTIFIED MAIL
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
July 11, 2002
RETURN RECEIPT REQUESTED
Mr. Robert York
1271 Eufola Road
Statesville, North Carolina 28677
SUBJ: Sigmon's Septic Tank Site
· Statesville, NC
Dear Mr. York:
The United States Environmental Protection Agency (US EPA) pursuant to the
authority and requirements of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) 42 U.S.C. §9601 et seq .. (the 'Superfund'
Law) is currently conducting an investigation of the release of hazardous substances
from the above referenced site. As you may know, the North Carolina Department of
Environment and Natural Resources (NC DENR) has already conducted two (2)
investigations and now, the US EPA is planning a more extensive study to determine the
chemicals present in the soil, groundwater and surface water/sediment and their location.
Therefore, in order to conduct this study, the US EPA requests your cooperation
by providing access to your property for the US EPA's personnel, contractors, and
representatives.
Please sign the enclosed access agreement and return it to the US EPA in the
self-addressed postage paid envelope no later than July 26, 2002. If you have any
questions, please give me a call at [phone].
Enclosure
zelle S. Bennett
Remedial Project Manager
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable• Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsumer)
• •
ACCESS AGREEMENT
1. I, ________ ~ am the owner of the property located at __________ _
and as such I have the authority to sign this authorization.
2. I grant authorization to the United States Environmental Protection Agency (EPA), its officers,
employees, contractors and other authorized representatives to enter the property located at __
_________ . This authorization allows EPA, its officers, employees, contractors and
other authorized representatives to have access to the property to conduct all actions necessary
to evaluate the nature and extent of contamination at the Sigmon's Septic Tank Site. EPA's
activities at the Site will include, but not be limited to, the following:
a. collect groundwater samples from drinking water wells and springs (if any);
b. collect soil samples;
c. clearing of debris, undergrow1h, and small trees, as necessary, to ensure access to
sample locations;
d. transport equipment onto and about the Site as necessary to accomplish the above
activities.
3. The consent for access and use granted herein will commence on August 1, 2002 and will
continue until EPA completes the above activities.
4. I realize that these actions by EPA are undertaken pursuant to its response and enforcement
responsibilities under the Comprehensive Environmental Response, Compensation and Liability
Act (Superfund), 42 U.S.C. Section 9601 et seq., as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) (Public Law 99-499).
5. Every effort will be made by the EPA representative to minimize the impact of this work. Your
yard will be completely restored if any disturbance occurs. All work will be performed at the
expense of EPA.
6. Please return this signed and dated Access Authorization to:
Name:
Giezelle S. Bennett, Remedial Project Manager
Environmental Protection Agency, Region 4
Sam Nunn Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
--------------Date: ---------
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EXPOSURE RESEARCH LABORATORY
ENVIRONMENTAL PHOTOGRAPHIC INTERPRETATION CENTER
12201 SUNRISE VALLEY DRIVE• 555 NATIONAL CENTER• RESTON, VA 20192
May 22, 2002
MEMORANDUM
SUBJECT:
FROivi:
TO:
Delivery Schedule for Sigmon 's Septic Tank Site, Statesville, North Carolina -. A! .-, ~ ' r. ., ,..... _." ; .. -') ' ,/ wan t:5OZJK, \..,SR,. ,p-,--,-_ .: __ y,•-~· ,,_.J,,_
Environmental Phtograph1c lnterpfetal!on Center
Landscape Ecology Branch
Giczelle Bennett
Environmental Scientist
Region IV
The proposed delivery schedule for the historical site analysis of the Sigmon's Septic
Tank site is as follows:
Prints: Three 9" x 9" print enlargements for each year of historical
imagery acquired. Due incrementally beginning June 7, 2002 with
with final delivery by July 3, 2002.
Historical Site Analysis: Three copies. Due September 30, 2002.
If you have any questions or problems concerning this project, please contact me at 703-
648-4288.
cc:
Carmen J. Santiago-Ocasio, R.S. Coordinator
Donald Garofalo, LEB/EPlC
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable OU Based Inks on Recycled Paper (Minimum 30% Postconsumer)
..
R.I' •
~®
•
BLACK & VEATCH
1145 Sanctuary Parkway
Suite 475
Black & Veatch Special Projects Corp.
Alpharetta, Georgia 30004 USA
Tel: [phone]
Fax: [phone]
US EPA -Region 4
Sigmon's Septic Tank Site
Remedial Investigation/Feasibility Study
Ms. Giezelle Bennett
U.S. Environmental Protection Agency Region 4
61 Forsyth Street, I J'h Floor
Atlanta, GA 30303
Subject: Additional cost estimates for soil screening
Dear Ms. Bennett:
Enclosed is the output of three scenarios for the soil boring screening using the Visual Sample Program.
The cost estimates used by the program for fixed planning and validation costs and fixed collection cost
per grid sample location were rounded from the previously submitted engineer's estimate of $50,000 and
$1,500, respectively. Per the previously submitted cost estimates, it was assumed that there would be no
costs associated with the cost of analysis for the screening samples. However, as indicated in the
attached email from today, in order to better characterize this area confirmatory analyses and
geotechnical analyses should be included in this effort and will be included in the budget for the scenario
you select, unless otherwise directed.
If you have any questions, please contact me at 770-521-8113.
CJ a
Enclosures
Sincerely,
Christoph ~~-Allen, P.E.
Project Manager
cc: Harvey Coppage, BYS PC RAC 4 Program Manager w/o enclosure
the imagine• build company111
Allen, Christopher J.
From:
Sent:
To:
Subject:
Giezelle:
•
Allen, Christopher J.
Wednesday, March 13, 2002 1 :32 PM
'[e-mail]'
RE: mobile lab
•
It is prery,ature to select dates for the field event until all the planning documents and budget have been approved.
However, if.Archie Lee knows when the mobile lab has availability everyone on the Sigmon project could use that as a
goal. I know that both you and I warit to see the fieldwork start as soon as possible.
The analytes that BV and the reviewers arrived at for the soil sampling grid include copper, iron, and lead using a portable
x-ray refraction (XRF) machine. It is likely that SESD would not need the full mobile lab for this and instead could just
send out one technician to perform the screening analyses. BV could rent an XRF machine; however, the time involved to
obtain a permit from North Carolina for a radioactive source (of which an XRF is) is considerable and would slow down the
start of the fieldwork.
One last thought: The cost estimates utilizing the VSP program assume no cost of analysis of the soil grid screening
samples. In the original FSP, BV proposed that all screened samples containing evidence of contamination would be
submitted to a fixed laboratory for confirmatory analyses (CLP full scan). The FSP estimated that 60 percent of the
screening samples would require confirmatory analyse_s. Considering the number of discrepancies no_ted between XRF
and confirmatory results generated by the contractor and fixed laboratory at the I LCO site (where I was last week) I am
now thinking that confirmatory analyses should be performed by a fixed laboratory. Also, one set of geotechnical analyses
(grain size distribution, pH, and TOC) per borehole were proposed in the original FSP; the geotechnical parameters may
be useful data for the RA. Unless otherwise directed, I will.include the cost of these confirmatory and geotechnical
analyses in the budget per the scenario you select.
Thanks again, cj
--Original Message-----
From: [e-mail] [SMTP:[e-mail])
Sent: Thursday, March 07, 2002 9:18 AM
To: [e-mail]
Subject: mobile lab
Chris, Archie Lee over at SESD said that he didn't think it would be a
problem to get the mobile lab, but I need to give him particulars so he
can book it. When (what week) and for what analytes?
Giezelle
1
. '
•
•
·Hotspot Sampling of 15284.3 MetersA2
100 · ·-___________________ 1_2_.2_0 __ m_e __ ter round hotspot_ ___ ~-------------__ _
.c:
/// .
/
0 60-,----------------,--'-/ _________________ _
/
~ //
I 40-1-----------r--/ ___ /_/--------------------,
; /
o-4-1~-1--,-,-.--1~-,-,,,,,-1----r-'7~1~-..-,-.--1---i-~1~7-,-,-,T-1~1-,7~-i~1-•-r,-r,7·..-,,-1~--,-.-,--,~---r•~~,.-,-,, ~1
0 5 10 15 20 25 30 35 40
Number of samples using a triangular grid
•
•
Hot Spot sampling with random start
of 1 sample area
covering 15284.33 square meters
using a ·26.8204 meter triangular grid.
There are 24 sample points
with a total cost of $86000.00.
There is a 74.9999% probability of hitting
a round hot spot with a radius of 12.1951 meters.
•
•
Area Number 1
X y X y X ____ . ____ Y_·-----··--· X y
502832.15 3952601. 35 502858.97 3952601. 35 502885.79 3952601.35 502912.61 3952601.35
502818.74 3952578.13 502845.56 3952578.13 502872.38 3952578.13 502899.20 3952578.13
502832.15 3952554.90 502858.97 3952554.90 502885.79 3952554.90 502912.61 3952554.90
502818.74 3952531.67 502845.56 3952531.67 502872.38 3952531.67 502899.20 3952531. 67 . '
502832.15 3952508.45 502858.97 3952508.45 502885.79 3952508.45 502912.61 3952508.45
502818.74 3952485.22 502845.56 3952485.22 502872.38 3952485.22 502899.20 3952485.22
•
•
.. ------··· ---------Grid Based Screening Sample Locations
Hot Spot 60' Radius, Triangular Grid 116', 75% Confidence Level
.---------------~.........------------_;__----
1 / I -, __ '~
I I '-.... ·-.....,
/( ' . '~,
(-/ I ' ',-~
/ ___ '~ _i:1 i :~~::::_ -
I
•
Hotspot Sampling of 15284.3 MetersJ\2
100 ______________ 1 __ 8_.2_9_m_e_te_r _round hotsp,_o_t~-
.c -/ 0 60-C------------------~
~
.c ra
-------,..,...---
.c / e 40-1-----------"'---//_· __ _.__~ -----'-------------1
C. /
~ 0
201-+-----~-----------·~----'------------~
l-.-l----T"'l-j'·-1-1-r-17-11'-f-1--1---.-J------.--1-,-1-,-!·'~l-i7-ri-1·-r,11-1-11,r-]--.l-'l'l
4 6 8 10 12 14 16 18
Number of samples using a triangular grid
•
•
Hot Spot sampling with random start
of 1 sample area
covering 15284.33 square meters
using a 40.2306 meter triangular grid.
There are 11 sample points
with a total cost of $66500.00.
There is a 74.9999% probability of hitting
a round hot spot with a radius of 18.2927 meters.
•
•
Area Number 1
X ________ Y~---
502831. 40 3952595.65
502891.74 3952560.81
502811.28 3952491.13
X
_502871.63
502831.40
·502051.51
y
3952595.65
3952525.97
3952491.13·
X
502911. 86
502871.63
502891.74
y
3952595.65
3952525.97
3952491.13
X
502851.51
502911. 86
y
3952560.81
3952525.97
•
Grid Based Screening Sample Locations
Hot Spot 80' Radius, Triangular Grid 155', 75% Confidence Level
== \\ ···· r·· -1 I
. /
...... ,, '-.. / /
'I ..... ··. ' /
! ·· 1 ~--.
i
•
•
Hotspot Sampling of 15284.3 MetersA2
100_, ____________ 2_4 __ .3_~ meter round -~-Qt~pot ________ -------~------_
···------------• /·
//
20-t-------,L----------------'--------------
/ 0--'T'T"'r-l~'l'-r-,----1•-1-1T'l'-1-ri-1i'TT"~7---.--1-'T'T7-r--r1-1-1-r-r!TTT ,i--r-1-1t7-l'l-,-1-1--r-1-···1-11'· r7-rT'-l'T1-1 I I l'T'l-ri-r
0 1 2 3 4 5 6 7 8 9 10
•
Number of samples using a triangular grid
Hot Spot sampling with random start
of 1 sample area
covering 15284.33 square meters
using a 53.6403 meter triangular grid.
There are 6 sample points
with a total cost of $59000.00.
There is a 74.9999% probability of hitting
a round hot spot with a radius of 24.39 meters.
. '
•
•
Area Number 1
X y
502821.29 3952599.15
502821.29 3952506.24
X
502874.93
502874.93
y l{ __ ----~Y_
3952599.15 502848.11 3952552.70
3952506.24
X y ---------·------------50290l.75 3952552.70
•
•
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
January 30, 2002
4WD-NSMB
Mr. Chris Allen
Black and Veatch
1145 Sanctuary Parkway, Suite 475
Alpharetta, GA 30004
SUBJ: Sigmon's Septic Tank Site
Statesville, NC
Dear Mr. Allen:
The Agency has reviewed the response to comments dated December 19, 2001.
Further clarifications are needed. Please provide this information no later than
February 19, 2002.
Please give me a call at 404-562-8824 if you have any questions.
o/4 ~ ;J>61
· zelle S. Bennett
Remedial Project Manager
Internet Address (URL) • http://www.epa.gov
H~cycted/Recyclable • Printed with Vegotablo Oil Based lnk·s on Recycled Paper (Minimum 30% Poslconsumer)
• •
COMMENTS
RI/FS RESPONSE TO COMMENTS DATED 12/19/01
EPA COMMENT 2 -Definitions from the Cambridge Dictionary of American English are
interesting, but the real issue here is that the photographs provided by the consultant
from their site inspection visit show that the topography has been modified. Altering the
language of the text to say this is a "pond/borrow pit" may be politically correct, but the
role of this feature in the operation of the site, and the impact of this site on the
surrounding area needs to be emphasized more than the name attached to this feature.
Water from precipitation, which would have run-off the site under natural conditions,
instead is channeled into the subsurface at the site of waste disposal. The photos
show that this has been happening for years. When the site was active, the additional
water helped dilute contamination in fluids added to the pond, but also supplied
additional fluid for leaching contaminants from subsurface soils and accelerated
groundwater velocities. The presence of wetlands vegetation shows that this process
has continued, even when the site has been inactive. Whether this process has
finished leaching contaminants from the soils, and whether the process has diluted
contaminants in groundwater sufficiently is unknown. Answering this question is one of
the purposes of the site characterization investigations.
This comment is especially iryiportant since the owner had stated that she would like to
fill it in. If ii is classified as a "borrow pit", ii would be easier to fill ii in, than if it is
classified as a "pond" or a "wetland." Therefore, simply revising the text does not
address this comment.
EPA Comment 7 -Regarding Soil Samples: The consultant has agreed to double the
spacing in the soil sampling grid, reducing the number to about half of the 365 soil
samples originally proposed. Little justification has been provided for the reduction or
for the original 365 samples.
The consultant may wish to considered a phased soil sampling approach designed
utilizing Visual Sample Plan. With this software, the confidence level obtained with
various sample spacings can be quantified, and the EPA Project Manager can see how
much extra confidence is obtained for 365 samples versus 160, 100 or even 50 spaced
at selected locations versus gridded locations. Visual Sample Plan can select sample
locations using random patterns, then calculate confidence levels and maximum size of
hot spots which might be missed with random spacing or gridded spacing. The
program can be used by assuming a budget for sampling, selecting a random sampling
pattern then evaluating the confidence level and size of a missed hot-spot which can be
obtained for the money available. Visual Sample Plan was developed by the Statistics
Resources group at the Pacific Northwest National Laboratory for the Department of
Energy.
-1 -
• •
The software is free and is available on the internet at http://dgo.pnl.gov/vsp/index.htm
It is recommended that a dxf file showing the boundaries and special features of the
site be created and used for a base map in Visual Sample Plan. Various soil sampling
. plans should be tested and the resulting confidence levels, maximum hot spot size and
related costs should be discussed with the EPA Project Manager. The dxf base map
file should be provided to the EPA Project Manager for review of the sampling plans.
The response states that "it is impossible to determine which former lagoons were
excavated", yet then goes on to say that "a grid-based approach ... from the non-
excavated lagoons ... from below excavated lagoons ... " If the location of the excavation
is notknown, then how can the rest of the paragraph be implemented? In addition, the
response states that "significant contamination still exists". How was this determined?
Regarding Surface Water & Sediment Samples: The consultant agrees to reduce the
· number of surface water and sediment samples from 20 to 11, based in part on the
Project Manger's objection to sampling more than one mile from the site before
conditions on-site are evaluated.
It should be noted that the first opportunity for surface water samples may be more than
one mile from the site. Local streams may be dry. The results of surface water
samples from down gradient may indicate groundwater pathways to surface water,
which could ultimately lead to savings in monitoring well installation. If the end of the
groundwater pathway can be defined using relatively inexpensive surface water
samples, the time and money savings could be large. Some cost savings might be
achieved by discarding the sediment samples during early, screening phases, if the
purpose of the surface water samples is to find groundwater pathways. If we assume
that pathways for groundwater to surface water are viable for volatile organics and
dissolved metals only, there may be little point in sediment analysis at larger distances
down gradient. Nearer to the source contaminants in sediment may indicate surface
water and sediment transport by erosion, but down gradient, detections may be from
other sources or may be from either surface water or groundwater impacts. The
inability to distinguish between these inputs may make sediment samples at larger
distances down gradient less appropriate at this time until transport mechanisms from
the site are better understood.
The consultant should identify the highest locations where surface water flows freely in
local drainages. T~is'evaluation should consider average and drought conditions.
Springs or seeps along valley walls should be identified. These data should be used to
selec! surface water sampling locations and justify the need to sample at greater
distances from the site.
-2 -
• •
Regarding Groundwater Monitoring Wells Samples: The EPA Project Manager feels the
Consultant's proposal for 12 temporary wells, 9 shallow wells, 8 deep wells and
sampling of 5 private wells is excessive. Review of the information presented suggests
that the Consultant's approach is essentially sound. The purpose of site
characterization activities is to determine the extent of contamination. This site is
difficult because of a perception that there may not be significant environmental
problems here. However, conditions at the site may be favorable to migration of
contaminants in groundwater over distances greater and deeper than might otherwise
be expected. The site is located on a topographic ridge which forms a surface water
divide. The release of contaminated water into unlined ponds probably was a major
source of man-made groundwater recharge for many years. These conditions suggest
that during operation of the site, a groundwater mound existed beneath the ponds,
which may have induced contaminated recharge to flow radially, 360° from the ponds.
Even if the size of the mound was not sufficient to overcome the natural hydraulic
gradient, groundwater flow from the mounded area was likely to have been semi-radial,
180° from the ponds.
Surface water divides often coincide with groundwater flow divides. The probable
location of the site on a groundwater flow divide compounds (he mounding effects of
the pond recharge, and makes a semi-radial groundwater/contaminant flow pattern
more likely. But more importantly, groundwater flow directions beneath a groundwater
flow divide typically are vertically downward, not horizontal. Therefore, sample results
from shallow temporary or permanent wells must be interpreted cautiously.
Determining the extent of contamination on a groundwater flow divide using only data
from shallow wells is likely to be ineffective and mis-leading.
A phased approach is recommended to the groundwater investigation at this site,
. based first on the development of a site-specific concept model for groundwater flow
and contaminant transport. The concept model would be tested, first by using results
from readily available sources such as existing on-site and off-site wells, and surface
water samples. Groundwater and surface water levels from these sources would be
used for preliminary estimates of groundwater flow directions and groundwater
velocities. These data should help determine whether any of the existing wells are on
or near probable flow paths from the site. These interpretations should be verified
using analytical results from surface water and private well samples.
EPA Comment 8 -The consultant agrees that the final locations will be selected
based on the results from the temporary wells sample results. The order in which the
work is to be accomplished and analyzed is important. It is recommended that the
surface water samples, plus groundwater samples from available existing wells, be
collected and analyzed first for indications regarding directions of contaminant
migration in groundwater. Second, a cluster of wells should be installed slightly down
gradient from the most likely source area. This monitoring well cluster should sample
the shallow, the saprolite and fractured-rock water bearing zones. The data from this
-3 -
• •
monitoring well cluster will help define the vertical hydraulic gradients and whether
pathways·to the deeper water bearing zones have been completed. If the hydraulic
gradients are strongly downward, and if the deeper water bearing zones are already
contaminated, then it may be possible to infer that the lateral extent of contamination in
the more shallow zones is relatively less important and can be estimated with relatively
few shallow temporary wells. In this case, efforts to delineate the extent of
contamination should focus on the deeper zones.
EPA Comment 13 -The proposed alteration of language describing the well purging
procedure remains arbitrary by setting a specified maximum duration for well purging (2
hours) during which the turbidity must be lowered to less than 10 NTUs. Specifying that
the tu-rbidity must be acceptable within two hours is not appropriate. Instead, site
specific conditions must be evaluated, sampling method options must be evaluated,
and the goal of reducing the turbidity to levels which make the sample useful must be
accomplished. Unfortunately, reduction in turbidity depends greatly on the method
used for sample collection, and these options vary greatly depending on the depth to
water in the well.
The Agency has had success during the last year using multiple variable speed
peristaltic pumps powered by motor cycle batteries which are installed to purge many
wells simultaneously for 6 or more hours, if necessary, then sample all of the wells
during a short period of time at the end of the day. This method may not be useable
where the depth to water exceeds 20-30 feet.
Essentially, this issue remains unresolved at this time. This issue must be reexamined
when site specific data regarding the depth to water in the wells is available. However,
there will be no filtering .
. EPA Comment 14 -The decision to begin numbering monitoring wells in this phase of
the investigation with the number 10 seems appropriate and should.help minimize
confusion with older wells.
EPA Comment 14 -The response that "Any data collected prior to the ES/ will not be
compared as they can not be data validated per the CLP program requirements" is
overly conservative and ignores the question: "Is the quality of the data suitable for the
proposed use?" The Data Quality Objectives (DQOs) must be evaluated rather than
simply specifying compliance with the CLP program. Twenty year old data from highly
contaminated wells may be very useful for evaluations of natural attenuation, especially
if the same well has been sampled a few times during subsequent years, then sampled
regularly as part of a monitoring program which meets current monitored natural
attenuation guidelines. If valid trends in contaminant concentrations versus time over a
few decades can be established, these may prove to be very informative and very
beneficial if a natural attenuation remedy is to be proposed for the site. Old data may
be annotated as not meeting current CLP standards, but it should not be discarded
without examination.
-4-
• •
EPA Comment 16 -Slug testing should occur only after the sample results are
available, and we verify we have a problem at this site and determine which
hydrogeologic units the problem is in. Otherwise, the rational described for the number
of slug tests and the zone which should be tested is sound.
EPA Comment 18 -The last part of this comment requests that PCBs be included in
the screening tables. The response is that PCBs were not detected. The maximum
detection limit should be included in the screening tables so that it can be assured that
detection limits were low enough to conclude that PCBs may be eliminated from the risk
assessment.
EPA Comment 23 -A list of species known or that would be found at the site based
on habitat types should be included in the ERA, specifically in Step 1 of the ERA
process. The response is that this list will be included in Step 3, the Problem
Formulation. The site visit has already been conducted and agencies have been
contacted. If.Steps 1 and 2 are being revised, recommend that this species list be
included, and not put off until Step 3. If the list will be not included until Step 3, then
the deviation from the national guidance should be expressed in the revision of Step 1.
EPA Comment 24 -It was previously requested that total PAHs be included in the
screening tables for soils, using ½ of the detection limit for individual PAHs that were
not detected. Black & Veatch respond that they propose using 1/10 of the detection
limit, rather than ½ of the detection limit. Using 1/10 of the detection limit is acceptable
in the refinement of COPCs, in Step 3, but should not be used in Step 2.
EPA Comment 43 -At a minimum, soil contaminant levels should be screened against
EPA's soil screening levels for the residential and construction worker scenarios.
EPA Comment 44 -Why are fish from the Davidson and/or Lamberth ponds not being
eaten? Are there too few fish? Is the pond not convenient to area fishermen? What is
the potential that this could be a human exposure pathway in the future? Please
discuss these issues in the BHHRA.
Additional Comment -Figure 2-6 -Before the PCOPCs can be eliminated from the
specific pathways, the physical/chemical information on each chemical (such as BCF,
BAF, and the Kaw) used to make the inclusion/exclusion decision will need to be
presented in the report.
- 5 -
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
Mr. Chris Allen
Black and Veatch
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
November 28, 2001
1145 Sanctuary Parkway, Suite 475
Alpharetta, GA 30004
SUBJ: Sigmon's Septic Tank Site
Statesville, NC
Dear Mr. Allen:
The Agency has reviewed the work plans for the above referenced Site dated
October 18, 2001 and comments are attached. Please provide a response to these
comments, not revised plans, no later than December 19, 2001.
Please give me a call at 404-562-8824 if you have any questions.
iezelle S. Bennett
Remedial Project Manager
Internet Address (URL)• http:!/www.epa.gov
Recycl,:,d/Flecyclable • Printed with Vcg~table Oil Aased Inks on RecyrJed Paper (Minimum 30% Postconsumer)
• •
COMMENTS
SIGMON'S SEPTIC TANK SITE
OCTOBER 18, 2001 DOCUMENTS
FIELD SAMPLING PLAN
1. Please include North on the maps. It is included on Figures 1-2 and 1-3 but not
on the other maps which are blowups of the original topo but sometimes rotated
90 degrees.
2. Page 2, Section 1.2 -Even though it is called a "pond" in previous documents,
before this term is carried through the RI, we need to determine if it really is a
'pond', or simply a big hole that has stayed open too long and collected water.
3. Page 4, Section 1.3 -Wastewaters and sludges are referred to prior to 1978. In
the period from 1978-1992, it is referred to as 'septic wastes'. Was this
wastewater, sludge, or both?
4. Include a legend on Figure 1-3. It is confusing which is a monitoring well or soil
sample location. This would also apply to the Figure 1.3 in the Draft Sampling
and Analysis Plan.
5. Page 6, 3rd paragraph -Delete the words "were installed" in the first sentence.
6. Section 2 -Nature and extent of contamination is only mentioned in terms of
groundwater. What about soil and surface water/sediment?
7. Section 3 -This section needs to be completely redone. The level of effort is too
much for a site of this magnitude and simply is not justified. Consider:
• In 1995, the "sludges" were excavated to a depth of 1 O feet. Therefore, the
highest amount of contamination should be in the waste pile samples (SST-009-
WS and SST-010-WS). Based on this, it seems hard to justify 365 soil samples
to determine the extent of slightly contaminated soil that may not present enough
of a hazard to excavate. In addition, because of the previous excavation, a ·
number of the samples may be fill dirt that was put in after the excavation.
• Twenty SW and SEO samples are proposed. The only contamination found
during the ESI was in the Davidson pond. In addition, samples are proposed in
-1 -
• •
areas that came up uncontaminated (SST -022, 023, and 024 -SW/SEO) during
the ESI. These are unnecessary. Determine the extent, if any, of the
contamination in on-site and surrounding sw/sed before venturing over one mile
from the site.
• For groundwater, this plan is proposing 12 temp, 9 surficial, and 8 deep wells in
addition to sampling 5 private wells. Considering the size of this site, this seems
excessive. Is all this information necessary to run an effective gw model at this
Site?
8. Why so many monitoring wells? Looking at Figure 3-1, if you use SS-MW-05A,
· why do you need SS-TW-02 and -05, or vice versa. Permanent wells are
preferred, but temporary wells can help decide where to put the permanent
wells. If B&V are proposing this method of locating permanent wells, why put the
locations of all these wells on the map. There are other examples of too many
wells close to each other. The ground water sampling locations need to be
modified to define the nature and extent of contamination in an efficient manner.
9. Figure 3-2. Why are there so many background soil samples (SS-SF/SB-101,
-102, and -103). Soil samples 107, 108, and 111 could probably be grouped for
one sample. The same for samples 114 and 113. Spacing for the grid sampling
in the lagoon area could be increased.
10. Figure 3-3. Please modify or include more justification for the amount of surface
water and sediment samples proposed.
11. Section 7.0: IDW from wells or decontamination fluids may not be dispersed on
the ground unless approval is obtained from the Mooresville Regional Office
Water Quality Section (704 663-1699).
12. Regarding the order in which the work proposed for this site should be
performed, it may be advisable to install the MW-02 well cluster before the
temporary wells are installed. The data obtained from the temporary wells
proposed for installation during the first phase of drilling may alter the locations
of other monitoring wells, but the MW-02 cluster has no directional sensitivity.
The MW-02 cluster includes a shallow surficial, a deep surficial and a bedrock
well. This monitoring well cluster is placed among the waste disposal ponds,
which are located exactly on the groundwater flow divide. Hydraulic gradients
beneath groundwater flow divides are vertical, not lateral. If these wells,
particularly the bedrock well, prove to be highly contaminated, or if contaminant
concentrations increase with depth, then the temporary shallow wells may will be
less important, and may not be necessary at all.
-2 -
• •
IF vertical hydraulic gradients prove to be greater than horizontal hydraulic
gradients, which often is the case on groundwater flow divides;
AND IF significant contamination is already in the bedrock,
THEN this will be sufficient proof that pathways to the bedrock have already
been completed. If these conditions are true, an entire phase of the proposed
investigation might be skipped. It would be more important to install additional
deep wells rather than spend funds on efforts to define the lateral extent of
groundwater contamination in the shallow zones. The only way to evaluate this
and save any money is to drill the MW-02 cluster first.
13. The historic sample analyses available for this site show that metals
contamination in groundwater will be an issue at this site. The proposed
investigation includes the use of temporary wells for determination of
groundwater flow directions and preliminary evaluations of groundwater quality.
Acquiring samples from temporary wells with turbidity less than 10NTUs, as
required by the Region 4 Standard Operating Procedure, is often difficult.
However, metals analyses from turbid samples are more likely to produce false
positive results than are metals analyses from samples where·the turbidity is
less than 10 NTUs. The Agency does not wish the Sigmon site characterization
to be burdened with metals analyses which are false positives. The Agency
does not wish to spend it's time or resources during the next few years arguing
whether the results from a particular sample are real or a false positive.
The text on Section 3 page 15/21 states that " ... a goal of 10 nephelometric
turbidity units will be attempted'. The text of Section 4 page 12/15 describes
additional specifications regarding purging of monitoring wells prior to sampling.
These specifications comply with the Region 4 SOP, which recommends that
monitoring wells be purged until the pH, temperature, turbidity and conductivity
have stabilized. However, because metals contamination in groundwater are an
issue at this site, it may be more appropriate for this site investigation to
subordinate the "stabilization" clause in favor of reducing the turbidity as much
as possible, preferably less than 1 0NTUs. This will avoid future comments and
hours of meetings over essentially pointless discussions of what the metals
concentrations might have been if the turbidity was lower.
The wells should be developed thoroughly after installation, then purged at the
lime of sampling with the specific goal of obtaining samples with low turbidity.
Specific measures should be implemented in the field to document the turbidity
of the water placed in the container designated for metals analysis. This might
include splitting a portion of the metals sample between the sample bottle and
the turbidity meter.
The Agency recommends that samples likely to produce reliable, useable
results be acquired and submitted for analysis. Any extra cost incurred in the
field for collecting low turbidity samples for metals analysis will be saved by
avoiding future arguments over ambiguous results.
-3 -
• •
14. The text of Section 1 page 6/19 describes samples from wells named MW1-4
installed along the western edge of the lagoons and south of the storage shed.
Concentrations of nitrates, barium, chromium, copper, iron, mercury, manganese
and lead in samples from these wells exceeded MCLs sometime in 1987. Wells
MW3 and MW4 were sampled again in June, 1990 when levels in excess of
North Carolina standards for iron, lead, manganese and mercury were found. In
light of this history, names of new wells installed during coming investigations
should avoid potential confusion with older wells at other locations which are up
to 15 years old. At first I thought new well numbers shown on Figure 3-1 stiould
be greater than 4. Then I noticed that two existing shallow wells are designated
at 8 and 9.
Eventually, contaminant concentrations from old sample events will be compared
with data from more recent events in natural attenuation evaluations. There
shouldn't be any ambiguity in sample names which may lead to incorrect data
interpretations. Names for new wells should consider well names and numbers
already used at the site.
15. Section 3 -Page 13 -Why would we field-screen for VOCs in the soil?
16. Section 3 -Page 19 -Is slug testing needed on all the permanent wells?
ECOLOGICAL RISK ASSESSMENT
GENERAL COMMENTS
17. This is a good first draft. However, the description of the operations of the facility
should be expanded, all data should be included, and a list of expected species
found in the area should be included. Screening tables should be revised.
18. All data should be used in this ecological risk assessment (ERA). During the
October 4, 2001 meeting, it was stated that NCDENR collected samples in 1987,
1990, and 1992. This ERA uses only data from the ESI. 1997 data from the
PA/SI is not used because the raw data were not available. This is
unacceptable. If the PA/SI data cannot be obtained from NCDENR, then the
RPM at EPA can provide you with the data. The soil screening table consists of
two surface soil samples, with the possibility of two other samples that might be
surface soil. The depths of these two samples, SS-017-SL and SS-018-SL, are
not identified in this report. Two or four surface soil samples for 15.35 acres is
not adequate to determine ecological risk. All other sampling events should be
considered, unless a removal action took place after samples were collected, but
the sampling effort should still be reported in the ERA, with an explanation why
those data were not used.
-4-
• •
Please describe the sampling procedures. For example, what were the depths
of the sediment samples? What physical/chemical parameters were collected
with the various media? For example, was soil pH taken? It is stated on Page
2-27 that low soil pH increases mobility of inorganic compounds. Were surface
water samples analyzed for hardness, DO, turbidity, total suspended solids,
etc.? Were total organic carbon and grain size determined in the sediment
samples? Weren't some of these samples background/reference samples?
They should be identified, and should not be included in the Step 2 screening
tables. Background/reference concentrations may be used in Step 3 in the
COPC refinement.
·· Toxicity of some of the metals in surface water varies with hardness. These
screening values should be adjusted based on hardness. If hardness was not
directly analyzed, then calcium and magnesium concentrations in the sample
may be used to calculate hardness, and then the screening values should be
adjusted accordingly.
Were pesticides analyzed in any previous sampling events? Pesticides are not
discussed in this report until the uncertainty section, so pesticides were not'
analyzed in the ESI. It was indicated during the October 4, 2001 meeting that
PCBs were analyzed in soil during one of the sampling events. PCB
concentrations are not found in any of the tables.
19. Screening tables usually contain the maximum concentration of each chemical.
These tables present all data from each station. The presentation of all sample
concentrations makes the review cumbersome in determining which chemicals
should be retained as COPCs and which should be eliminated. If these tables
are revised to include only the maximum concentration, please identify station
locations.
Some of the chemicals presented in the soil screening tables have Region 4
screening values that are not used in this table. Some examples of Region 4
screening values that were not used in this report are dichlorobenzene and vinyl
chloride. Some of the soil screening values are for groups of chemicals, and can
be applied to a specific chemical that was analyzed. Some of the 'generic'
screening values that can be applied to specific chemicals are aliphatic
chlorinated hydrocarbons and chlorophenols. The application of these screening
values will pare down the list of COPCs.
Generally, the screening tables include a final column that indicates if the
chemical should be retained as a COPC or eliminated as a COPC. This makes
the review easier.
20. Please include a table of acronyms.
- 5 -
• •
SPECIFIC COMMENTS
21. Page 1-2, § 1.0 Introduction: Three bullets describe how the SERA provides the
risk manager with information. While the first two bullets are basically correct,
the third is not. The third bullet states the ecological risks determined in the
SERA be managed by the implementation of a remedy, and continuation of the
ERA would not provide any additional value. Please see Page 2-5 of the
Process Guidance (USEPA 1997) for the three possible decisions at the end of
Step 2 of the ERA, and revise this section.
The second bullet states that a possible decision after Step 2 of the ERA
-process is to continue on to Steps 3 through 8. Another SMDP (scientific
management/decision point) is conducted at the end of Step 3, and it may be
determined that the ERA is completed at this point, and Steps 4 through 8 are
not required. Please revise this bullet to reflect to continue to Step 3, and not
Steps 3 through 8.
22. Page 2-1, § 2.1.1 Facility Description: Please expand on the facility operations.
The only information in this report is that this was a septic tank pumping and
waste operation starting in 1970. As per the Process Guidance (USEPA 1997)
on Page 1-2, information from the site history and from reports related to the site
should be utilized to describe the type of facility and identify what the suspected
contaminants are. Describe the wastes that were brought to this facility (i.e.,
what are the suspected contaminants?). During the October 4, 2001 meeting, it
was stated that wastes from industrial, residential, and commercial companies
were brought to this facility. What types of companies were these, and what
types of chemicals would potentially have been in their wastes? This information
would provide some idea of what types of contaminants might be found at this
site. It is mentioned in the Site Visit Letter Report (Allen, 2001) that International
Paper Company brought drums to this facility, and that these drums, now rusted
and empty, are found near the storage shed. If it is possible, records should be
obtained to determine if International Paper Company brought wastes here after
the chlorination process. It may be that dioxins/furans may be a potential
contaminant.
What is the regulatory history of this company? It was stated in the October 4,
2001 meeting that NCDENR collected samples in 1987, 1990, and 1992. Did
this company have any permits to discharge water from the lagoons to a
stream? If a permit was used, were there ever any exceedances of allowed
. limits? Did the lagoons ever flood and possibly flow into the stream?
On Page 2-7 of this report, it is stated that 6 above ground storage tanks are
found in the old field habitat. This is the only information in the ERA. The Site
Visit Letter Report (Allen, 2001) indicates that approximately 46,000 gallons of
- 6 -
• •
liquid waste are currently stored in these tanks, although the ERA states that no .
waste disposal activities occurred in this area. No samples were collected
during the ESI in this area. Has any previous sampling occurred in this area? If
not, this appears to be a data gap, and is not mentioned as a data gap in the
uncertainty section on Page 2-39.
23. § 2.1.2 Ecological Habitats: This section should include a list of species that
would be found in the habitats described. The list should include both the Latin
and vernacular names of plants and animals. An asterisk should identify which
species (or evidence like rabbit scat) were observed during the site visit or during
previous visits.
24. Table 2-2 Ecological Screening of Contaminants Analyzed in Surface Soils: This
table should include only surface soils. Sample SS-011-WS is a sample
collected from 1-3' below ground surface, and samples SS-012-WS, SS-0113-
WS, and SS-113-WS are samples collected from 1-4' below ground surface.
Remove these samples from the surface soil screening table.
This table does include a total PAH concentration. This is the sum of detected
PAHs. Please include a total PAH concentration that includes ½ of the detection
limit for individual PAHs that were not detected with the detected concentrations
for comparison.
25. Table 2-2: The US EPA Region IV screening values for general chemical
groupings, such as Aliphatic Chlorinated Hydrocarbons, Monocyclic Aromatic
Hydrocarbons, and Chlorinated Hydrocarbons should be used for contaminants
that fall into these categories but do not have a specific screening value
associated with them. Please correct.
The US EPA Region IV screening value for vinyl chloride is 10 ppb. Please add.
The US EPA Region IV screening value for dichlorophenols (total) of 3 ppb can
be used for 2,4-dichlorophenol. Please correct.
The US EPA Region IV screening value for chlorophenols (each) of 10 ppb can
be used for 2-chlorophenol. Please correct.
The US EPA Region IV screening value for phthalates (total) of 100 ppb can be
used for phthalates that have no specific screening value. Please correct.
26. Typographical/editorial comments: Page 2-12, Potential Receptors: The term
populations should be used rather than communities. Mallards are omnivores,
not herbivores. Figure 2-6, Potentially Complete Exposure Pathways: Generally,
COPCs are not listed in this flow chart. Omnivores and carnivores may also be
-7 -
• •
exposed to contaminated sediments. Omnivores may be exposed to
contaminated soils.
27. Pages 2-26 and 2-27: The arguments presented in sections 2.1.5.1 and 2.1.5.2
seem to imply that if these contaminants are not biologically transferred in the
terrestrial or aquatic environments, there is no problem. It should be noted that,
if present in high enough concentrations, direct effects on receptors could take
place. Contaminants do not necessarily need to be biologically transferred in
order to have ecological significance.
28. Table 2-5 -Tetrachloroethene and Tetrachloroethylene are the same compound
-and one should be deleted under Type Ill PCOPc,
29. The risk assessment methodology and conclusions presented in the SERA are
sound. While the conservative nature of the assessment likely overestimates
site risks to environmental receptors, this is acknowledged in the document and
is appropriate for a screening level assessment. The selected list of Potential
Receptors is acceptable. Based on the analytical data presented in the SERA,
the Service concurs with the list of Preliminary Contaminants of Potential
Concern (PCOPC) retained for further study.
30. Review of the SERA revealed a few items which should receive particular
attention in the next phase of the ecological risk evaluation for this site:
o The PCOPCs are, for the most part, not strongly persistent or bioaccumulative.
Future ecological risk assessment work at the site should focus on the lower
tropic levels (such as the Terrestrial Producers, Terrestrial Invertebrates, Aquatic
Producers, Aquatic Invertebrates, and Benthic Invertebrates). The PCOPCs,
their concentrations, and the small areal extent of contamination at the site
appear to indicate less concern for upper trophic level receptors (i.e., likely do
not need much attention on aquatic and terrestrial mammals and birds).
o The Threatened and Endangered Species section adequately captures the list of
rare species known from Iredell County; based on the site description, it is
unlikely that the site will be of concern with regard to federally-listed threatened
and endangered species.
o Analytical data tables for sediment should specify whether results are being
presented on a wet weight, or dry weight, basis.
o The characterization of site fauna and flora is very general, and it would be
beneficial to add detail on the habitat types and the organisms observed using,
and expected to use, the site (i.e., give species lists in addition to the general
descriptions).
- 8 -
• •
o The Contaminant Fate and Transport section is also very general. More
integration of the chemical behavior data with the physical attributes of this site
would be desirable for future ecological risk documents.
o Unless pesticides were used at the site or in the wastestreams handled by the
site, the Service does not consider the absence of these data to be a significant
concern (see Conclusions in the SERA).
o Unless some indication of waste handling activities at the northern end of the site
becomes available, the absence of analytical data for surface water pathway 1 is
not a significant concern to the Service (see Conclusions in the SERA).
BASELINE RISK ASSESSMENT
31. Section 1, last 2 paragraphs of pg 4; Section 3 -References. The full
references for "NCDC,2000" and "USDC, 1961" are not listed in Section 3.
32. Section 1, pg 6-operational history. The text here discusses the discharge of
the wastewater from 1970 to 1978, but only mentions what was done with the
sludge from 1973 to 1974 (land applied to area farms). What was done with the
sludge prior to 1973 and after 197 4?
33. Section 1, pg 7, para 3 -previous investigations. What is a "septic T"? Is it
known if the pond waters that were used for irrigation purposes were applied to
food crops?
34. Section 1, pg 9, para 3 -previous investigations. For the chemical
concentrations listed, is it known which represent surface soil and which
represent subsurface soil samples?
35. Section 1.4, Page 16 of 18: Since the US EPA Region IX PRGs are now used to
screen COPCs, it is not necessary to use the US EPA Region Ill RBCs.
36. Tables 1-1, 1-2, 1-3 -Analytical results for ESI soil, groundwater, and surface
water samples. Definitions, references, and explanations should be provided
for PRGs, NC Soil Values, EPA SSLs, Federal MCLs, NC 2L Standards, NC
Freshwater Standards, and EPA Freshwater SWSV values. For arsenic, the
newly promulgated MCL of 10 µg/L should be included as a "To Be Considered"
value.
37. Tables 1-1 to 1-3: The purpose of these tables is unclear. Information
presented in these tables will appear in RAGS Part D Tables 2.x for each
- 9 -
• •
exposure scenario. It appears as though no attempt was made to ensure that
SQLs for non-detects were below screening levels, which will need to take place
in the RAGs D Tables 2.x. Please explain the purpose of these tables or delete
them and provide a detailed COPC screen in the RAGs D Tables 2.x. Also, for
the RAGs D Tables 2.x, there are currently no NC Soil Values (undefined in
Table 1-1) that are accepted as screening values for human health risk
assessment purposes. There are accepted methodologies for the calculation of
soil to groundwater concentrations, but this information normally does not
appear in the human health risk assessment.
38. Section 2.1.2: An evaluation of detection levels vs. screening levels will need to
• take place. If DL > SL, the contaminant cannot simply be dropped from
consideration. This process took place in the Screening Level Ecological Risk
Assessment, and must take place in the Human Health Risk Assessment.
Evaluation of these situations must be consistent with RAGs Part A. Please
reword and resubmit this section.
39. Section 2.1.2.1, pgs 2,3 Risk-Based Screening. The text here could be slightly
reworded to better explain the purpose and function of the risk-based screening
process. Revise: " ... will not be considered further in the BHHRA because it is
very unlikely that chemical concentrations at or below the RBSCs would
contribute significantly to a risk or hazard." to read: " ... will not be considered
further in the BHHRA because chemical concentrations at or below the RBSCs
. would not contribute significantly to an unacceptable risk or hazard."
40. Section 2.1.2.1, second paragraph: There are no human health risk-based
screening concentrations for sediment. Please correct.
41. Section 2.1.3: The COPC screen should take place in RAGs D Tables 2.x. Also,
please list the sources of the proposed screening toxicity values in this section.
42. Figure 2-1: Please explain how both on-and off-site residents can be exposed
to surface water and sediment via ingestion and dermal contact, but only off-site
residents are assumed to eat the fish.
43. Figure 2-1 and Table 2-1: Please evaluate the inhalation route for residents'
exposure to surface soil and construction workers' exposure to subsurface soil.
44. Figure 2-1 -Conceptual Site Model. The note: "Fish will only be quantitatively
evaluated if it is determined that site-related COPCS are in the Davidson or
Sliwinski ponds" seems to leave ambiguity as to what exactly has been done
and how it will be decided to assess this pathway. Do any data currently exist,
or are there plans to collect samples for sediment, surface water, and/or fish in
these ponds? Are fish from these ponds currently being caught and eaten?
-10 -
• •
45. Table 2-2; Section 2.2.4, pgs 10 to 13 -exposure assumptions. Rationale and
explanation are needed for values based on "professional judgement", especially
the exposure frequency values for the trespasser, construction worker, and
offsite resident.
46. Table 2-2: Please explain how an offsite resident could access sediment 52
days/year, but access the surface water covering the sediment only 45
days/year? Please replace all footnote "c" items (professional judgement) with
information cited from other sources.
47. Section 2.2.4.1, 2.2.4.2, pg 12 -exposure to residents. The exposure to the
-current resident(s) is not clear. A current exposure scenario should attempt to
assess exposure that is believed to be occurring at present. Appropriate
exposure parameter values for current residents should be used. These values
will not necessarily be the same as the default exposure _values that would be
appropriate to use for a future scenario.
48. Section 2.4.2, pg 24, eq. 2.9 -intake term. The "I" (intake) term here is
equivalent to the "DI" term (includes the chemical concentration component) in
Equation 2.1 (riot to the HIF term in Eq.2.1, as stated here).
WORK PLAN VOLUME 1 and 2
49. Groundwater modeling hours should be moved from Task 12 (FS Report) to
Task 6 (Data Evaluation).
50. Task 13 -Responsiveness Summary hours are included already in Task 2
(Community Relations). The proposed plan and ROD will be prepared by the
RPM, and there will not be three (3) meetings that the contractor will have to
attend.
51. Task 14 will be minimal. There are not any active PRPs at this time.
-11 -
NORTH CAROLINA
DEPARTMENT OF ENVJR~ENT AND NATURAL RESOURCES
DIVISION OF WASTE MAN~NT
MICHAEL F. EASLEY, GOVERNOR
WILLIAM G. Ross,JR., SECRETARY
DEXTER R. MATTHEWS, INTERIM DIRECTOR
Ms. Giezelle Bennett
26 November 2001
Superfund Branch. Waste Management Division
US EPA Region IV
61 Forsyth Street, S. W.
Atlanta, Georgia 30303
•
SUBJECT: Review of Remedial Investigation Feasibility Study: Draft Sampling and Analysis
Plan Volume I-Quality Assurance Project Plan Sampling and Analysis Plan, Work
Plan Volume I, Volume 2 Field Sampling Plan, Screening Level Ecological Risk
Assessment Steps I and 2, Health and Safety Plans, and Baseline Risk Assessment
Work Plan
Sigmon's Septic Tank
Statesville, Iredell County
Dear Ms. Bennett:
The Superfund Section of the Division of Waste Management has reviewed the above documents.
The documents are all dated October 18, 2001 except September 25, 2001 for HASP and received
by the Division on 19 October 200 I. The following comments are offered:
Health and Safety Plan
No comments.
Volume I-Work Plan
Section 2.4 will need to be modified to reflect the changes requested in Section 3 of the Field
Sampling Plan.
Volume 2-Field Sampling Plan
Include a legend on Figure 1-3. It is confusing which is a monitoring well or soil sample location.
This would also apply to the Figure 1.3 in the Draft Sampling and Analysis Plan
Please include North on the maps. It is included on Figures 1-2 and 1-3 but not on the other maps
which are blowups of the original topo but sometimes rotated 90 degrees.
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE: [phone] \ FAX: [phone]
AN EQUAL OPPOR11JNITI'/ AffiRMA TIVE ACTION EMPLOYER • 50% RECYCLED/IO% POST-CONSUMER PAPER
i
r,
'.\ ,.
'
Why so many monitoring wells? Looking at Figure 3-1. If you use SS-MW-05A, why do you need
SS-TW-02 and -05, or vi.ersa. I prefer permanent wells but te'8rary wells can help decide
where to put the permane ells. If they are proposing this method'II!!' locating
permanent wells, why put the locations of all these wells on the map. There are other examples of
too many wells close to each other. The ground water sampling locations need to be modified to
define the nature and extent of contamination in an efficient manner.
Figure 3-2. Why are there so many background soil samples (SS-SF/SB-101, -102, and -103). Soil
samples 107, 108, and 111 could probably be grouped for one sample. The same for samples 114
and 113. Spacing for the grid sampling in the lagoon area could be increased.
Figure 3-3. Please modify or include more justification for the amount of surface water and sediment
samples proposed.
Section 7 .0: IDW from wells or decontamination fluids may not be dispersed on the ground unless
approval is obtained from the Mooresville Regional Office Water Quality Section (704 663-1699).
Baseline Risk Assessment Work Plan
Attached are comments from Mr. Dave Lilley.
Screening Level Ecological Risk Assessment Steps 1 and 2
Attached are comments from Mr. Dave Lilley.
If you have any questions, please call me at 919/733-2801 ext. 350.
Sincerely, .
_., /, /} -)·/)_ ,.l-v1
?/t,u·1Cf I!,/~ -(
Nile P. Testerman, PE
Environmental Engineer
Superfund Section
I I\
'P
North Carolina
Department of Environment a.atural Resources • ·~;~ ~·· ____ ,.,,
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
TO:
FROM:
RE:
I. No comments.
DL/dl/word/shsp/20
., ma, ___ _
October 26, 200 I NCDENR
Nile Testerman
David Lilley J) 7S L
Comments on the Health and Safety Plan for the
Remedial Investigation/Feasibility Study for Sigmon 's
Septic Tank Site, Statesville, Iredell County, NC
September 25, 200 I
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: wwv.•.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ I 0% POST CONSUMER PAPER
North Carolina
Department of Environment a.atural Resources •.. ~,.~ ~----·" Division of Waste Management m _, ___ _
Michael F. Easley, Governor
William G. Ross Jr., Secretary MCDEMR
Dexter R. Matthews, Interim Director
November 19, 2001
TO: Nile Testerman
FROM:
RE:
David Lilley 'J)j? L
Comments on the Screening Level Ecological Risk
Assessment, Steps 1 and 2, Remedial
Investigation/Feasibility Study, Sigmon's Septic Tank site,
Statesvi!le, Iredell County, NC
October 18, 2001
I. Table 2-2: The US EPA Region IV screening values for general chemical
groupings, such as Aliphatic Chlorinated Hydrocarbons, Monocyclic
Aromatic Hydrocarbons, and Chlorinated Hydrocarbons should be used for
contaminants that that fall into these categories but do not have a specific
screening value associated with them. Please correct.
2. Table 2-2: The US EPA Region IV screening value for vinyl chloride is I 0
ppb. Please add.
3. Table 2-2: The US EPA Region IV screening value for dichlorophenols
(total) of 3 ppb can be used for 2,4-dichlorophenol. Please correct.
4. Table 2-2: The US EPA Region IV screening value for chlorophenols (each)
of IO ppb can be used for 2-chlorophenol. Please correct.
' 5. Table 2-2: The US EPA Region IV screening value for phthalates (total) of
100 ppb can be used for phthalates that have no specific screening value.
Please correct.
6. Figure 2-6: Before PCOPCs can be eliminated from specific pathways, the
physical/chemical information on each chemical (such as BCF, BAF, and log Kow ) used to make the inclusion/exclusion decision will need to be presented
in the report.
7. Pages 2-26 and 2-27: The arguments presented in sections 2.1.5.1 and 2.1.5.2
seem to imply that if these contaminants are not biologically transferred in the
terrestrial or aquatic environments, there is no problem. It should be noted
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.em.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ I 0% POST CONSUMER PAPER
• •
that, if present in high enough concentrations, direct effects on receptors could
take place. Contaminants do not necessarily need to be biologically
transferred in order to have ecological significance.
Dl/dl/word/EcoRA.doc/46,4 7
,. r. r ' i
North Carolina
Department of Environment a&atural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary November 20, 2001
Dexter R. Matthews, Interim Director
TO: Nile Testerman
FROM:
RE:
David Lilley ]) E? L
Comments on the Baseline Risk Assessment Work Plan,
Remedial Investigation/Feasibility Study, Sigmon's Septic
Tank Site, Statesville, Iredell County, NC
October 18, 200 I
I. Section 1.4, Page 16 of 18: Since the US EPA Region IX PRGs are now used
to screen CO PCs, it is not necessary to use the US EPA Region III RBCs.
2. Tables 1-1 to 1-3: The purpose of these tables is unclear. Information
presented in these tables will appear in RAGS Part D Tables 2.x for each
exposure scenario. It appears as though no attempt was made to ensure that
SQ Ls for non-detects were below screening levels, which will need to take
place in the RA Gs D Tables 2.x. Please explain the purpose of these tables or
delete them and provide a detailed COPC screen in the RAGs D Tables 2.x.
Also, for the RAGs D Tables 2.x, there are currently no NC Soil Values
(undefined in Table 1-1) that are accepted as screening values for human
health risk assessment purposes. There are accepted methodologies for the
calculation of soil to groundwater concentrations, but this information
normally does not appear in the human health risk assessment.
3. Section 2.1.2: An evaluation of detection levels vs. screening levels will need
to take place. If DL > SL, the contaminant cannot simply be dropped from
consideration. This process took place in the Screening Level Ecological Risk
Assessment, and must take place in the Human Health Risk Assessment.
Evaluation of these situations must be consistent with RA Gs Part A. Please
reword and resubmit this section.
4. Section 2.1.2.1, second paragraph: There are no human health risk-based
screening concentrations for sediment. Please correct.
5. Section 2.1.3: The COPC screen should take place in RAGs D Tables 2.x.
Also, please list the sources of the proposed screening toxicity values in this
section.
6. Figure 2s 1: Please explain how both on-and off-site residents can be exposed
to surface water and sediment via ingestion and dermal contact, but only off-
site residents are assumed to eat the fish.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFF!RMA TIVE ACTION EMPLOYER -50% RECYCLED I I 0% POST CONSUMER PAPER
• •
7. Figure 2-1 and Table 2-1: Please evaluate the inhalation route for residents'
exposure to surface soil and construction workers' exposure to subsurface
soil.
8. Table 2-2: Please explain how an offsite resident could access sediment 52
days/year, but access the surface water covering the sediment only 45
days/year? Please replace all footnote "c" items (professional judgement)
with information cited from other sources.
DL/dl/word/HumanHealthRA.doc/67,68
North Carolina • Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
TO:
FROM:
RE:
November 20, 2001
Nile Testennan
David Lilley }) B' L
Comments on the Baseline Risk Assessment Work Plan,
Remedial Investigation/Feasibility Study, Sigmon's Septic
Tank Site, Statesville, Iredell County, NC
October 18, 2001
1. Section 1.4, Page 16 of 18: Since the US EPA Region IX PRGs are now used
to screen COPCs, it is not necessary to use the US EPA Region III RBCs.
2. Tables 1-1 to 1-3: The purpose of these tables is unclear. Information
presented in these tables will appear in RAGS Part D Tables 2.x for each
exposure scenario. It appears as though no attempt was made to ensure that
SQLs for non-detects were below screening levels, which will need to take
place in the RA Gs D Tables 2.x. Please explain the purpose of these tables or
delete them and provide a detailed COPC screen in the RAGs D Tables 2.x.
Also, for the RAGs D Tables 2.x, there are currently no NC Soil Values
(undefined in Table 1-1) that are accepted as screening values for human
health risk assessment purposes. There are accepted methodologies for the
calculation of soil to groundwater concentrations, but this information
normally does not appear in the human health risk assessment.
3. Section 2.1.2: An evaluation of detection levels vs. screening levels will need
to take place. IfDL > SL, the contaminant cannot simply be dropped from
consideration. This process took place in the Screening Level Ecological Risk
Assessment, and must take place in the Human Health Risk Assessment.
Evaluation of these situations must be consistent with RAGs Part A. Please
reword and resubmit this section.
4. Section 2.1.2.1, second paragraph: There are no human health risk-based
screening concentrations for sediment. Please correct.
5. Section 2.1.3: The COPC screen should take place in RAGs D Tables 2.x.
Also, please list the sources of the proposed screening toxicity values in this
section.
6. Figure 2-1: Please explain how both on-and off-site residents can be exposed
to surface water and sediment via ingestion and dermal contact, but only.off-
site residents are assumed to eat the fish.
I 646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ IO% POST CONSUMER PAPER
• •
7. Figure 2-1 and Table 2-1: Please evaluate the inhalation route for residents'
exposure to surface soil and construction workers' exposure to subsurface
soil.
8. Table 2-2: Please explain how an offsite resident could access sediment 52
days/year, but access the surface water covering the sediment only 45
days/year? Please replace all footnote "c" items (professional judgement)
with information cited from other sources.
DL/dl/word/HumanHealthRA.doc/67,68
North Carolina • • Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
TO:
FROM:
RE:
November 19, 2001
Nile Testerman
David Lilley VI? L
Comments on the Screening Level Ecological Risk
Assessment, Steps I and 2, Remedial
Investigation/Feasibility Study, Sigmon's Septic Tank site,
Statesville, Iredell County, NC
October 18, 200 I
I. Table 2-2: The US EPA Region IV screening values for general chemical
groupings, such as Aliphatic Chlorinated Hydrocarbons, Monocyclic
Aromatic Hydrocarbons, and Chlorinated Hydrocarbons should be used for
contaminants that that fall into these categories but do not have a specific
screening value associated with them. Please correct.
2. Table 2-2: The US EPA Region IV screening value for vinyl chloride is I 0
ppb. Please add.
3. Table 2-2: The US EPA Region IV screening value for dichlorophcnols
(total) of 3 ppb can be used for 2,4-dichlorophcnol. Please correct.
4. Table 2-2: The US EPA Region IV screening value for chlorophcnols (each)
of IO ppb can be used for 2-chlorophenol. Please correct.
5. Table 2-2: The US EPA Region IV screening value for phthalates (total) of
100 ppb can be used for phthalatcs that have no specific screening value.
Please correct.
6. Figure 2-6: Before PCOPCs can be eliminated from specific pathways, the
physical/chemical information on each chemical (such as BCF, BAF, and log
K0w) used to make the inclusion/exclusion decision will need to be presented
in the report.
7. Pages 2-26 and 2-27: The arguments presented in sections 2.1.5.1 and 2.1.5.2
seem to imply that if these contaminants are not biologically transferred in the
terrestrial or aquatic environments, there is no problem. It should be noted
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] I FAX: [phone] I Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ IO¾ POST CONSUMER PAPER
• •
that, if present in high enough concentrations, direct effects on receptors could
take place. Contaminants do not necessarily need to be biologically
transferred in order to have ecological significance.
D 1/d I/word/Eco RA.doc/46,4 7
• • United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33 726
Raleigh, North Carolina 27636-3726
November I 6, 200 I
Ms. Giezelle Bennett, Remedial Project Manager
Waste Management Division
U.S. Environmental Protection Agency
Atlanta Federal Center
61 Forsylh Street.
Atlanta, Georgia 30303-8960
Dear Ms. Bennett:
Thank you for requesting comments from the U.S. Fish and Wildlife Service (Service) on the
Screening Level Ecological Risk Assessment (SERA) for the Sigmon's Septic Tank Site,
Statesville, Iredell County, North Carolina. Service comments are based on review of the
document only, we did not have time for a reconnaissance of the site in meeting your requested
date for comments. We may have additional comments and perspective for your use once a site
visit is conducted. Service comments are provided pursuant to the Fish and Wildlife Coordination
Act, as amended (16 U.S.C. 66 !-667e) and the Endangered Species Act of 1973, as amended ( 16
U .S .C. 1531-1543 ). These comments are intended as technical assistance for the U.S.
Environmental Protection Agency's assessments and planning conducted pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended
(42 U.S.C. 9601 et seq.); they do not represent any position that the U.S. Department of the
Interior may adopt concerning possible injury to natural resources under their trusteeship.
The risk assessment methodology and conclusions presented in the SERA are sound. While the
conservative nature of the assessment likely overestimates site risks to environmental receptors,
this is acknowledged in the document and is appropriate for a screening level assessment. The
selected list of Potential Receptors is acceptable. Based on the analytical data presented in the
SERA, the Service concurs with the list of Preliminary Contaminants of Potential Concern
(PCOPC) retained for further study.
Review of the SERA revealed a few items which should receive particular attention in the next
phase of the ecological risk evaluation for this site:
o The PCOPCs are, for the most part, not strongly persistent or bioaccumulative. Future
ecological risk assessment w_ork at the site should focus on the lower tropic levels (such as
the Terrestrial Producers, Terrestrial Invertebrates, Aquatic Producers, Aquatic
Invertebrates, and Benthic Invertebrates). The PCOPCs, their concentrations, and the small
• •
areal extent of contamination at the site appear to indicate less concern for upper trophic
level receptors (i.e., likely do not need much attention on aquatic and terrestrial mammals
and birds).
o The Threatened and Endangered Species section adequately captures the list of rare species
known from Iredell County; based on the site description, it is unlikely that the site will be
of concern with regard to federally-listed threatened and endangered species.
o Analytical data tables for sediment should specify whether results are being presented on a
wet weight, or dry weight, basis.
o The characterization of site fauna and flora is very general, and it would be beneficial to add
detail on the habitat types and the organisms observed using, and expected to use, the site
(i.e., give species lists in addition to the general descriptions).
o The Contaminant Fate and Transport section is also very general. More integration of the
chemical behavior data with the physical attributes of this site would be desirable for future
ecological risk documents.
o Unless pesticides were used at the site or in the wastestreams handled by the site, the
Service does not consider the absence of these data to be a significant concern (see
Conclusions in the SERA).
o Unless some indication of waste handling activities at the northern end of the site becomes
available, the absence of analytical data for surface water pathway I is not a significant
concern to the Service (see Conclusions in the SERA).
Thank you for the opportunity to comment; we appreciate being involved at this early stage in the
Remedial Investigation/ Feasibility Study process for this site. If you have any questions
regarding this letter, please contact me at tom_ [e-mail] or 919/856-4520 ( ext. 21 ).
Sincerely,
T~Alit:t
Ecologist
North Carolina •
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
TO:
FROM:
RE:
1. No comments.
DL/dl/word/shsp/20
October 26, 200 I
Nile Testerman
David Lilley D 5 L
Comments on the Health and Safety Plan for the
Remedial Investigation/Feasibility Study for Sigmon's
Septic Tank Site, Statesville, Iredell County, NC
September 25, 2001
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: 919-7 I 5-3605 \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ I 0% POST CONSUMER PAPER