NCD095458527_19940623_FCX Inc. (Statesville)_FRBCERCLA FS_Feasibility Study OU-2 - Revision 1-OCR

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I Document Control No. 4400-11-ADYQ
I Revision 1
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I FEASIBILITY STUDY
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FCX-STATESVILLE SUPERFUND SITE I OPERABLE UNIT 2
STATESVILLE, NORTH CAROLINA
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I Work Assignment No. 11-498M
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I JUNE 1994
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I U.S. EPA CONTRACT NO. 68-W9-0057
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I Roy F. Weston, Inc.
1880-H Beaver Ridge Circle
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Norcross, Georgia 30071
I WESTON W.O. No. 04400-011-021-0109-00
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I Document Control No. 4400-11-ADYQ
I Revision 1
I
I FEASIBILITY STUDY
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I FCX-STATESVILLE SUPERFUND SITE
OPERABLE UNIT 2
STATESVILLE, NORIB CAROLINA
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Work Assignment No. 11-498M
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I JUNE 1994
I
I U.S. EPA CONTRACT NO. 68-W9-0057
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I Roy F. Weston, Inc.
1880-H Beaver Ridge Circle
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Norcross, Georgia 30071
I WESTON W.O. No. 04400-011-021-0109-00
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Prepared by:
Rcce,veo
AUG 2 6 1994
FCX-STATESVILLE SUPERFUND S ''OOPERFUNo
OPERABLE UNIT 2 secr,ON
FEASIBILITY STUDY
REVISION 1
STATESVILLE, NORTH CAROLINA
U.S. EPA Contract No. 68-W9-0057
Work Assignment No. 11-498M
Document Control No. 4400-11-ADYQ
JUNE 1994
Ralph P. McKeen, P.E.
Date: ___,tf'i"-L../4---"-2,?-1--/2-+-i-
Performed by: /~ /"i · Technical Review fJ.. • /7 ~
'BrianR. Magee, P.E. Date: G/J-3/'fi
Approved by:
Approved by: _____________ _ Date: ______ _
Ken Mallary
U,S, EPA Remedial Project Manager
Approved by: _____________ _ Date: ______ _
Robert P, Stem
U.S. EPA Regional Project Officer
WESTON W.0. No. 04400--011--021--0109-00
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in.whole or in part, without the express written permission of EPA
TABLE OF CONTENTS
Section
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
-1 . INTRODUCTION ....................................... 1-1
I.I
1.2
1.3
1.4
1.5
Site Overview . 1-2
1.1.1 Site Description .................................. 1-4 1.1.2 Chronological Development of the Site . . 1-7 1.1.3 Alleged On-Site Pesticide Burial . . 1-8
Summary of Past Investigations . . . .
Findings of the Phase I RI . . . . . . .
. 1-9
. 1-9
I. 3. I Soil Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9 1. 3. 2 Groundwater Results . . . . 1-12 1.3.3 Surface Water Results . . . . . 1-12 I. 3 .4 Exploratory Boring Results . . 1-15
Scope of the Phase II RI . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-15
Phase I and Phase II RI Combined Results . . . . . . . . . . . . . . . . . . . 1-17
1.5.1 Lithology and Hydrogeology 1-17 1.5. 2 Contamination Overview 1-19
1.5.2.1
1.5.2.2
1.5.2.3
1.5.2.4
Pesticides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-19
Dioxin/Furan Analyses ........................ 1-22
Other Organic Compounds . . . . . . . . . . . . . . . . . . . . . . 1-22
Metals .................................. 1-23
1.5 .3 Contaminant Migration Through Soil .................... 1-23
1.5.3.1
1.5.3.2
1.5.3.3
Pesticides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-23
Volatile Organic Compounds . . . . . . . . . . . . . . . . . . . . . 1-24
Metals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-24
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Section
1.6
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Title
1. 5 .4 Contaminant Migration Through Groundwater
1.5.4.1
1.5.4.2
1.5.4.3
Pesticides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Volatile Organic Compounds .................... .
Metals ................................. .
1.5.5 Chemical Characterization of Surface Water and Sediment
Results of the Supplemental EPA Sampling
1-25
1-25
1-25
1-27
1-27
1-28
1.6.1 Extractable Organics and Pesticides/PCBs ................. 1-29 1.6.2 Dioxins/Furans ................................. 1-29
2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS .. 2-1
2.1
2.2
2.3
Introduction . . . . . . . . . . . . . . . . . . . . . . .
Identification of ARARs . . . . .
FederalARARs ................... .
. ...... 2-1
. 2-2
.. 2-4
2.3.1 Resource Conservation and Recovery Act (RCRA) ............ 2-4
2.3.1.1
2.3.1.2
2.3.1.3
Chemical-Specific ARARs ...
Location-Specific Requirements
Action-Specific Requirements .
. 2-17
2-19
2-19
2.3.2 Clean Water Act ................................ 2-29
2.3.2.1
2.3.2.2
Chemical-Specific Requirements .
Action-Specific Requirements ..
2-29
2-34
2.3.3 Safe Drinking Water Act ........................... 2-35
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This document was prepared by Roy F. Weston, Inc., expressly for EPA lt shall not be released or disclosed, in whole or ln part, without the express written permission of EPA.
Section
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: l
Date: June 1994
TABLE OF CONTENTS (Continued)
2.3.3.1
Title
Chemical-Specific Requirements . . 2-36
. 2-40 2.3.4 Clean Air Act . . . . . . . . . . . . . . . . . . . . . . . . . .
2.3.4.1
2.3.4.2
National Ambient Air Quality Standards (NAAQS) . . . . . . . 2-40
National Emission Standards for Hazardous Air Pollutants
2.3.5
2.3.6
2.3.7
2.3.8
2.3.9
2.3.10
2.3.11
2.3.12
(NESHAP) Standards ......................... 2-41
Occupational Safety and Health Act .................... 2-41
Hazardous Materials Transportation Act ................. 2-42
Protection of Wetlands . . . . . . . . . . . . . . . . . . . . . 2-43
Floodplain Management ................... · ........ 2-44
Regulations Protecting of Landmarks, Historical, and
Archeological Sites .............................. 2-44
Endangered Species Act . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-46
Fish and Wildlife Coordination Act . 2-46
EPA OSWER Soil Screening Levels .................... 2-47
2.4 State ARARs ..................................... 2-47
2.4.1
2.4.2
2.4.3
2.4.4
2.4.5
2.4.6
North Carolina Hazardous Waste Management Rules and
Solid Waste Management Law ....................... 2-47
North Carolina Water and Air Resources Act . . . . . 2-49
North Carolina Drinking Water Act .................... 2-49
North Carolina Water Pollution Control Regulations .......... 2-49
North Carolina Drinking Water and Groundwater Standards ..... 2-50
North Carolina Surface Water Quality Standards ............ 2-52
2.4.6.1
2.4.6.2
2.4.6.3
Surface Water Classification ..................... 2-52
Standards for Toxic Substances and Temperature ........ 2-58
Water Quality Standards Applicable to Surface Waters
of North Carolina ........................... 2-59
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Section Title Page
2-60
3
4
2.4.6.4 Surface Water Quality Standards Applicable to FCXS
2.4. 7 North Carolina Air Pollution Control Regulations ............ 2-60
REMEDIAL OBJECTIVES ................................ 3-1
3.1
3.2
3.3
3.4
Regulatory Requirements .
Soil Remediation Goals . .
3.2.l Risk Assessment Results
Treatment/Disposal Standards . . . . . . . .
Summary of Soil Remediation Levels and
Treatment/Disposal Standards ....... .
. 3-1
. 3-2
. 3-3
. 3-4
. 3-4
IDENTIFICATION AND SCREENING OF REMEDIAL
TECHNOLOGIES ...................................... 4-1
4.1
4.2
4.3
4.4
No Action ........................................ 4-2
Institutional Controls . . ............................ 4-3
4.2.l Deed Restrictions
Containment Technologies
. 4-3
. 4-4
4.3. l Capping ..................................... .4-4
Removal Technologies ................................ 4-5
4.4. l Excavation .................................... 4-5
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Section
4.5
4.6
4.7
4.8
4.9
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Physical Treatment Technologies .. ......................
Page
. 4-6
4.5.1
4.5.2
4.5.3
4.5.4
Soil Washing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6
Stabilization/Solidification ........................... 4-7
Soil Flushing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11
In-Situ Volatilization (ISV) ........................ 4-12
Chemical Treatment Technologies .......................
4.6.1
4.6.2
4.6.3
Wet Air Oxidation .....
Supercritical Water Oxidation .....
Dechlorination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. 4-14
. 4-14
. 4-15
. 4-16
Thermal Treatment Technologies . . . . . . . . . . . . . . . . . . . . . . . . . 4-17
4.7.1
4.7.2
4.7.3
Incineration . . . . . . . . . . . . . . . . .
Thermal Desorption . . . . . . . . . . . .
Vitrification ....................... .
Biological Treatment Technologies ...... .
4. 8.1 Bioremediation/Bioreclamation (In-Situ) ................ .
4. 8.2 Bioslurry .................................. .
Disposal Options .
4.9.1
4.9.2
On-Site Landfill
Off-Site Landfill
...............................
. 4-18
. 4-21
. 4-22
. 4-24
. 4-24
. 4-25
. 4-26
. 4-27
. 4-28
4.10 Summary ....................................... 4-29
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Section
-5
6
.DEVELOPMENT AND SCREENING OF REMEDIAL ACTION
ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1
5. I Introduction ....................................... 5-I
5.2 Summary of Remedial Goals ............................ 5-2
5. 3 Development and Screening of Remedial Alternatives ............. 5-4
DETAILED EVALUATION OF REMEDIAL ALTERNATIVES ......... 6-1
6.1
6.2
6.3
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6-1
.. 6-2 Evaluation Criteria
6.2.1
6.2.2
6.2.3
6.2.4
6.2.5
6.2.6
6.2.7
Compliance with Applicable or Relevant and Appropriate
Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2
Short-Term Effectiveness ........................... 6-3
Long-Term Effectiveness and Permanence ................. 6-3
Overall Protection of Human Health and the Environment . . . . 6-3
Reduction of Toxicity, Mobility, and Volume of Contaminants . . . . 6-4
Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4
Cost ........................................ 6-5
Alternative I -No Action ... . 6-7
. 6-7
. 6-7
. 6-7
6.3.1
6.3.2
6.3.3
6.3.4
6.3.5
6.3.6
6.3.7
6.3.8
Description of Alternative
Compliance with ARARs
Short-Term Effectiveness
Long-Term Effectiveness and Permanence ................. 6-8
Overall Protection of Human Health and the Environment . . . . 6-8
Reduction of Toxicity, Mobility, or Volume of Contaminants ..... 6-9
Implementability ................................. 6-9
Cost .................................. : ..... 6-9
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Section
6.5
6.6
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Alternative 2 -Limited Action/Capping . 6-9
6.4.1
6.4.2
6.4.3
6.4.4
6.4.5
6.4.6
6.4.7
6.4.8
Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-9
Compliance with ARARs . . . . . . . . . . . 6-11
Short-Term Effectiveness . . . . . . . . . . 6-15
Long-Term Effectiveness and Permanence ................ 6-15
Overall Protection of Human Health and the Environment ...... 6-15
Reduction of Toxicity, Mobility, or Volume of Contaminants . . . . 6-16
Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16
Cost ....................................... 6-16
Alternative 3 -Building Demolition with Capping . 6-18
6. 5 .1 Description of Alternative . 6-18
6.5.2 Compliance with ARARs . 6-18
6.5.3 Short-Term Effectiveness . 6-20
6.5.4 Long-Term Effectiveness and Permanence ................ 6-20
6.5 .5 Overall Protection of Human Health and the Environment . . . . 6-21
6.5.6 Reduction of Toxicity, Mobility, or Volume of Contaminants .... 6-21
6.5.7 Implementability ................................ 6-21
6.5.8 Cost ....................................... 6-21
Alternative 4 -Soil Excavation and Medium-Temperature Thermal
Desorption With BCD .......................... . . 6-23
6.6.1
6.6.2
6.6.3
6.6.4
6.6.5
6.6.6
6.6.7
Description ................................... 6-23
Compliance with ARARs . . . . . . . . . . . 6-27
Short-Term Effectiveness .......................... 6-27
Long-Term Effectiveness and Permanence ................ 6-28
Overall Protection of Human Health and the Environment ...... 6-29
Reduction of Toxicity, Mobility, and Volume .............. 6-29
Implementability ................................ 6-30
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Section
7
6.6.8 Cost .......... . . 6-30
6.7 Alternative 5 -High Temperature Thermal Desorption ............ 6-32
6.8
6.7.1
6.7.2
6.7.3
6.7.4
6.7.5
6.7.6
6.7.7
6.7.8
Description ................................... 6-32
Compliance with ARARs . . . . . . . . . . . 6-34
Short-Term Effectiveness .......................... 6-34
Long-Term Effectiveness and Permanence ................ 6-35
Overall Protection of Human Health and the Environment ...... 6-36
Reduction of Toxicity, Mobility, and Volume ............... 6-36
Implementability ................................ 6-36
Cost ....................................... 6-37
Soil Alternative 6 -Soil Removal & Off-Site Incineration . 6-37
6.8.1
6.8.2
6.8.3
6.8.4
6.8.5
6.8.6
6.8.7
6.8.8
Description ................................... 6-37
Compliance with ARARs . . . . . . . . . . . 6-40
Short-Term Effectiveness .......................... 6-41
Long-Term Effectiveness and Permanence ................ 6-42
Overall Protection of Human Health and the Environment . . . . . . 6-42
Reduction of Toxicity, Mobility, and Volume .............. 6-43
Implementability ................................ 6-43
Cost . . . . . . . . . . . . . . . . . . . . . . . . ............ 6-43
COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . . . 7-1
7.1 Evaluation Criteria Comparison ........................... 7-1
7.1.1.
7.1.2
7.1.3
7.1.4
Overall Protection of Human Health and the Environment ....... 7-1
Compliance with ARARs . 7-2
Short-Term Effectiveness . 7-2
Long-Term Effectiveness . . 7-5
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Section
7.1.5
7.1.6
7.1.7
7.1.8
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
Title
Reduction of Toxicity, Mobility, and Volume
Implementability .
Costs ...
Summary .....
Page
.. 7-5
. 7-6
. 7-7
. 7-7
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Figure No.
1-1 Site Location Map
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
LIST OF FIGURES
Title
1-2 Monitoring Well Locations
1-3 Phase I RI DDT Concentration in Soils .
1-4 Pesticide Concentrations in Groundwater .................. .
Page
. 1-3
. 1-6
1-11
1-13
1-5 VOC Compound Concentrations in Groundwater, Phase I RI 1991-1992 ..... 1-14
1-6 Surface Water Sampling Locations ................... .
1-7 Overall Distribution of Pesticides in Groundwater Phase II RI, 1992
1-8 Tetrachloroethene Distribution in Groundwater Overburden Wells,
3-1
6-1
Phase II -

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992 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Approximate Excavation Areas Based on Cleanup Levels
Soil Sample Locations Exceeding Cleanup Goal ..... .
6-2 Approximate Areas to be Capped (Alt. 2) Based on Cleanup Goals
6-3 FCX-Statesville Feasibility Study Cost Estimate;
Alternative 2 Capping with Deed Restrictions .
6-4 Proposed Location of Investigation Trenches .
6-5 Typical Process Schematic of MTTD with BCD
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1-16
1-20
. 1-21
. 3-6
6-12
6-14
6-19
6-25
6-26
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Revision: 1
Date: June 1994
TABLE OF CONTENTS (Continued)
LIST OF TABLES
Table No. Title
-1-1 Summary of Investigations Prior to RI at FCXS
2-1 Summary of ARAR Sources Evaluated
2-2 Analysis of Potential Federal ARARs .
1-10
. 2-5
. 2-6
2-3 Analysis of Potential State of North Carolina ARARs ................. 2-14
2-4 Land Disposal Restrictions Assumed to be Applicable to Soils at the FCXS Site 2-31
2-5 Federal Surface Water Quality Standards for FCXS Contaminants of Concern 2-31
2-6 Current and Proposed Federal Safe Drinking Water Act Standards
for FCXS Contaminants of Concern . . . . . . . . . . . . . . . . . . . 2-37
2-7 Superfund Proposed Soil Screening Levels for Residential Land Use ....... 2-48
2-8 North Carolina Class GA Groundwater Quality Standards for FCXS
Chemicals of Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....... 2-53
2-9 North Carolina Surface Water Quality Standards for FCXS Chemicals
of Concern ................................... . . 2-61
3-1 Soil Remediation Levels
5-1 Soil Remediation Levels
5-2 Screening of Alternatives
.................... ' ............. .
..................................
................................
. 3-5
. 5-3
. 5-5
6-1 Samples Exceeding Cleanup Goals and Estimated Contaminated Soil Volumes .. 6-13
6-2 Cost Estimate, Alternative 2 -Capping With Deed Restrictions ........... 6-17
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: Table of Contents
Table No.
LIST OF TABLES (Continued)
Title
Revision: 1
Date: June 1994
6-3 .cost Estimate, Alternative 3 -Bldg. Demolition With Capping ....
6-4 Cost Estimate, Alternative 4 -Soil Excavation and MTTD with BCD
6-5 Cost Estimate, Alternative 5 -High Temp. Thermal Desorption
6-6 Cost Estimate, Alternative 6 -Off-Site Soil Incineration . . . . .
6-4 Cost Estimate, Alternative 4 -Soil Excavation and MTTD with BCD
6-5 Cost Estimate, Alternative 5 -High Temp. Thermal Desorption
6-6 Cost Estimate, Alternative 6 -Off-Site Soil Incineration
7-1 ARARs Compliance Summary ....
7-2 Evaluation of Remedial Alternatives
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XII
6-22
6-31
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6-44
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. 7-3
. 7-8
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
SECTION 1
INTRODUCTION
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
The Feasibility Study (FS) is the mechanism for the development, screening, and detailed
evaluation of alternatives for remedial actions. The primary objective of the FS for the FCX-
Statesville (FCXS) Superfund Site in Statesville, North Carolina, is to develop and evaluate
remedial action alternatives for the site which are capable of mitigating unacceptable
environmental risks as detennined in the baseline Risk Assessment (RA). The approach and
structure of the FS are in accordance with the U.S. Environmental Protection Agency's (EPA)
Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA
(1988). The FS is based on the characterization of the site from the Remedial Investigation (RI),
Phases I and II, and the potential impact of the site on human health and the environment as
evaluated in the baseline RA.
The objectives of the remedial action at FCXS are to:
•
•
Remediate the possible environmental and human health impacts by reducing
contaminant levels, exposure, or both in compliance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA, also known as Superfund), the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and state-established regulations for the
site.
Enable delisting of the site from the National Priorities List (NPL) after
completion of remediation.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
The FS (and subsequent remediation) at FCXS has been divided into three operable units (OUs).
The FS for OU-I, which addressed groundwater, surface water, and sediment contamination that I has been sufficiently characterized to propose remediation where needed, was issued in May
1993. The FS addressed OU-I groundwater in both the saprolite and bedrock beneath the FCXS
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property and in the saprolite downgradient at FCXS. Surface water and sediment on and
downgradient of the FCXS property was also evaluated as part of OU-I. This report covers
OU-2, which addresses the soil contamination characterized on, under, and in the immediate
vicinity of the FCXS property.
Additional on-site and off-site contamination that has not been fully characterized will be further
investigated separately as OU-3 so as not to delay the implementation of remedial measures for
OU-I and OU-2. OU-3 will cover all remaining contamination, including the off-site bedrock
aquifer, a surface seep north and upgradient of FCXS, and other contamination on nearby
properties. Past FCXS operations are not believed to have contributed to detected contamination
in these other areas. Additional areas of study may be added to OU-3 as data are collected.
1.1 SITE OVERVIEW
A detailed description of the site is provided in the Phase I and Phase II RI Reports (October
and November 1992, respectively). A summary of the information contained in the RI reports
is provided in this section.
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~. ;;:_·....:...'9;,.,_ '~c:--;r(, -:<>,m~.,..;
• FIGURE NORTH CAROLINA
SITE LOCATION MAP
FCX-STATESVILLE
STATESVILLS~[E J~QORTH CAROLINA
½ 0 I MILE =======================
IOOOS::::ESCE3:0==::::l:,000eea=eeee1ee000C:::::=:::::::'OOOE=ee=ee4000a:::::=::::::5000::iee=ee=ee6ee000C:::::=~1000L_ F(ET
SOURCE, STATESVILLE WEST, N.C. (1969) CONTOUR INTERVAL 10 FEET
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This document was prepared by Roy F. Weston, Inc., expressly for EPA lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
1.1.1 Site Description
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
FCX is located on Highway 90 approximately 1.5 miles west of downtown Statesville, North
Carolina, at the intersection of Phoenix Street and West Front Street (Figure 1-1). The area is
-characterized by the presence of light and heavy industry, small businesses, residential
neighborhoods, and a school in the immediate vicinity. The coordinates of the site are latitude
35 ° 47' 11" north, longitude 80° 54' 58" west.
The site covers approximately 5.5 acres and is bounded by the Norfolk-Southern Railroad and
Burlington Industries (fonnerly Beaunit Mills) to the north, the Carnation Milk Company to the
west, a small business/residential area immediately south of West Front Street, and a pre-
fabricated utility shed retailer lot east of Phoenix Street.
The site is currently abandoned. The dominant on-site structure is a warehouse located on the
western half of the property. It consists of two attached structures: an upper building,
constructed in 1968 or 1970, and a smaller, lower building constructed in 1982. The area south
of the warehouse is paved except for a narrow grass strip along the sidewalk. The eastern half
of the site is dominated by a large concrete pad, 6 inches to 7 inches thick, 62 feet wide, and
I 90 feet long, extending from the eastern end of the warehouse along the north property line.
The area south of the pad is covered almost entirely with approximately 6 to 12 inches of
crushed, compacted gravel. Several smaller areas within this area, mostly tractor trailer pads
and parking area, are paved with either concrete or asphalt.
The area, except for the paved area between the warehouse and West Front Street, is completely
fenced, mostly with chain-link fencing. The fence is in good condition and access is gained via
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Phoenix Street through a 36-foot wide gate along the eastern end of the site. The gate is locked
with a heavy chain and padlock.
A small, vacant two-story brick building is located at the southeastern corner of the site just
-beyond the eastern fence. This building housed offices while FCX was in operation. Most of
the area between the eastern fence and Phoenix Street is covered with grass except for the area
occupied by the building.
There are two known underground tanks present at the site; a 7 ,500-gallon gasoline storage tank
and a 10,000-gallon diesel fuel storage tank. These tanks are located in the front parking area
near the fuel pumps, where the upper and lower sections of the warehouses join. These tanks
were checked during the RI and were determined to be essentially empty. The east tank
contained 0.67 feet of water; the west tank contained 0.05 feet of petroleum product floating
above 0.22 feet of water. There has been no reported leakage from the tanks nor does
groundwater data from nearby monitoring wells indicate that any significant leakage has occurred
(EPA RI Report, 1992).
A total of 12 permanent groundwater monitoring wells are on the FCXS property, as well as one
well further downgradient (Figure 1-2). Four were installed in 1986 as part of a pre-purchase
environmental evaluation conducted for Southern States Coopera_tive. Four were installed in
I 989 in conjunction with the removal action conducted by US EPA, and five were installed in
June 1991 for the RI.
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LEGEND
• MONITORING WELL
0 TEMPORARY MONITORING WELL
!1-.;:s;;:;ou;;,:;R;,;:CE;;.' .::'";;;,A.;;:S';,:,".:;"AP;;:;.:;(';;;";.;;,"';,;,";,;,;'l:..., ______________________ -t
o FIGURE 1-2
"' I X
MONITORING WELL LOCATIONS
FCX -STATESVILLE
STATESVILLE, NORTH CAROLINA
i:'a..;o;;;;RA;;;;WN;.;BY;,;;·.,;J;;;.c;;.. _____________________ ...., ______ ..
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
1.1.2 Chronological Development of the Site
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Based on the available file information, it appears that FCX began operations at the Statesville
site as an agricultural supply distribution center circa 1940 and continued to operate until
-bankruptcy in September 1986. Prior commercial use of the site, if any, is not known. It
appears that two main activities were conducted at the site. Initial operations consisted of the
formulation, repackaging, warehousing, and distribution of farm chemicals, primarily pesticides
and fertilizer, and the milling and sale of feed grains. These activities were initially restricted
to the eastern two-thirds of the site. Initial operations also consisted of the cleaning and
treatment of seed grains, apparently with mercury-containing compounds.
The facility was EPA licensed to manufacture or repackage pesticides including, at various
times, DDT, DDD, lindane, chlordane, malathion, aldrin, heptachlor, and a tobacco spray,
probably MA-30. Notable spillage is reported to have occurred at the transfer areas.
At some time after 1950-195 I, the site underwent several structural and operational changes.
The western half of the horseshoe-shaped building in the center of the site was demolished and
the upper (western) portion of the current warehouse was constructed, extending the building to
near the property line adjoining Carnation Milk Company. The smaller building adjoining the
feed milling and bagging buildings, at the intersection of Phoenix Street and the railroad tracks
near the northeastern corner of the site, was also removed. Repackaging of liquid pesticides
ceased in 1966. Dust repackaging was discontinued in 1969. The only known significant
operational and structural changes that occurred after 1969 were the repackaging of rat bait in
the early 1980s and construction of the lower portion of the warehouse in 1982.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
1.1.3 Alleged On-Site Pesticide Burial
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
In 1966, approximately 10,000 pounds of DDT, DDD, and possibly liquid chlordane were
allegedly buried in 2 adjacent trenches, approximately 10 feet deep. The material was
-supposedly a mixture of powders and liquids in a variety of packaging, including paper bags,
glass jars, and other types of typical consumer packaging. After burial was completed, the
trenches were backfilled with 6 feet of on-site soils and a reinforced 8-inch thick concrete slab
was placed over the area. The upper portion of the current warehouse was constructed on the
poured slab. According to a previous FCX employee, the possibility exists that the trenches
were ?bliterated soon after burial during extensive construction-related grading. During this
time, other packages were taken to the old Statesville landfill.
During the site reconnaissance on February 12, 1991, conducted by EPA-Environmental Services
Division (EPA-ESD), a previous employee of the construction company responsible for much
of the historical site demolition and construction was interviewed. He indicated that he and
other employees were instructed to place various bagged and bottled pesticides in a hole located
in the current vicinity of the northeast comer of the lower portion of the warehouse. The hole
was apparently located within approximately 35 feet of the railroad tracks. Possible locations
could range from the inside comer of the lower section of the warehouse to a location beneath
the large concrete slab east of the building.
An additional reconnaissance was conducted in April 1991. At that time, interviews with FCX
employees indicated that an additional pit, possibly a product mixing pit, was originally located
within the horseshoe-shaped building. The approximate location beneath the current warehouse
floor coincides with an elevator-like structure visible in historical photographs.
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This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shalt not be released or disclosed, in whole or in part,
without the express written permission of EPA.
1.2 SUMMARY OF PAST INVESTIGATIONS
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
The site has no previous enforcement history; however, there have been several sampling
investigations, of varying scope, at FCXS. These investigations were conducted by the North
-Carolina Department of Human Resources (NCDHR), US EPA, and Fred C, Hart for Southern
States Cooperative, one-time potential purchasers of the site. A summary of these investigations
conducted prior to the RI is presented in Table 1-1.
1.3 FINDINGS OF THE PHASE I RI
During the summer and early fall of 1991, USEPA Region IV conducted an inhouse Phase I RI
at FCXS. The investigation involved extensive sampling (237 samples) of on-and off-site soil,
groundwater, surface water, and sediment. Significant findings are summarized in this section.
1.3 .1 Soil Resu Its
Contamination from DDT and its degradation products, DDD and DDE, was detected at FCXS.
The highest concentrations of contaminants were detected beneath the floor of the upper section
of the warehouse, in the general area where an in-ground pesticide mixing pit was located.
Concentrations of DDT as high as 830,000 micrograms per kilogram (ug/kg) were reported for
this area. Figure 1-3 shows the distribution and concentrations of DDT at the site. DDD and
DDE concentrations were lower than those observed for DDT, and their respective distribution
patterns were so mew hat more restricted. The highest concentrations were gene rail y restricted
to the upper two feet of soil, with only the highest contaminated area containing contaminant
concentrations as deep as four feet or greater.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Investigations
Fred c: Hart Assoc.
February 1986
NCDHR Site Inspection
May 1986
EPA Hazard Ranking System
June 1988
EPA (WESTON•SPER)
Emergency Response
Jaouary 1989
EPA (WESTON•SPER)
Emergency Response
August 1989
EPA (O.H. Materials)
Emergency Response
Jaouary 1990
NUS Screening Site
Inspection at Burlington
Industries, August 1990
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Table 1-1
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Summary of Investigations Prior to RI at FCXS
Findings
Chlordaoe, DDT, aod other pesticides in soil. Gamma-BHC aod other pesticides
in groundwater. Trichlorofluoromethaoe (TFM), trichloroethylene (TCE), and
other volatile orgaoic compounds (VOCs) also found in groundwater.
Groundwater data suspect due to lack of QA/QC.
VOC plume more extensive, with chlorinated solvents in wells east and west of
the warehouse and in a deep well on Carnation property. Lindaoe in MW-3.
Fluorocarbons in upgradient well. Caprolactum in all on-site wells. Chlordaoe,
DDT, and dieldrin in soil around warehouse and in residential yard across street.
FCX scored 37.93 based solely on groundwater. Placed on NPL in February
1990.
No evidence of pesticide burial observed in approximately 30 borings.
All eight wells showed halocarbon contamination, with PCE predominating.
Highest halocarbon concentrations in deep well MW-SD aod shallow well MW-1.
TFM high in MW-4. Pesticides, primarily BHC isomers, in all wells except
MW-6 aod MW-6D.
Halocarbon groundwater contamination in all eight wells, with PCE
predominating. TFM high in MW-4. Pesticides found in MW-1 aod MW-3.
Study included sampling of FCXS wells MW-6 aod MW-6D. Toluene in MW-
6D. Low levels (J-values) of other volatile compounds in each well.
1-10
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f usoj oor ca-iCENTRATIC:W (PPB}
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---- - --
BURLINGTON
INDUSTRIES
· 0 150 300 ◊
-- --·--
BASE M~ S0JRCE: EPA STE MIP Cl-l1Ell43
: SCALE FEET ◊
i------------------------,----_: ____ --,::,-,=-"""="'"""'-:=----------1
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(_)
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FCX-STA TESl.1LLE
STATESl.1LLE, NORlli CAROLINA
PHASE 1 RI DDT CONCENTRATIONS IN SOILS
FIGURE 1-3
ORA\JN
CHECKED
D.O.
APPROVED ATE
\I, □, NO.
04400-01-02
Dw'G. N□.
04400006
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This document was· prepared by Roy F. Weston, Jnc., expressly for EPA. ft shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Chlordane (and its constituents) and dieldrin were also detected in the soils but were not detected
at the levels observed for the DDT compounds, nor do they appear to be widespread. Only I minor, isolated occurrences of DDT compounds and chlordane were observed in samples
collected from off-site areas; therefore, off-site DDT contamination was not considered
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-significant.
1.3.2 Groundwater Results
Samples from on-site monitoring wells indicated that both the surficial (saprolite) and bedrock
portions of the groundwater system beneath the site are contaminated with pesticides, primarily
lindane, BHC compounds, endrin ketone, and chlordane. Figure 1-4 shows the distribution and
concentrations of pesticides detected in groundwater samples from on-site monitoring wells.
A variety of chlorinated solvents was detected in groundwater samples from on-site monitoring
wells, as well as in the process well located on the Carnation property west of the site. The
most significant contaminant observed was tetrachloroethylene (PCE), with concentrations in
excess of 100 micrograms per liter (ug/L) being detected. Figure 1-5 shows the concentrations
of the identified compounds.
1.3.3 Surface Water Results
Analytical results from surface water and sediment samples collected during the Phase I
investigation did not appear to indicate surface water contamination with any fom1 of
contaminants known to be associated with FCXS. Significant chlorinated solvent contamination,
however, was detected in a surface water sample collected at a location immediately north of
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6 04400-1-93
Alpho-BHC -Q.33
Beto-BHC -0.13
Oelta-BHC -O.DI 5
Endrin -0.022 NORTH
Endrin Ketone -0.39
Gommo-BHC {lindone)-0.17
Alpho-BHC-5.4
Belo-BHC -4.8
Ch lord one -

1

.1 0elto-BHC -2.9
Dieldrin -0.13
Endrin Ketone -3.1 Camrna-BHC (lindone)-16
Alpho-BHC -0.85
Beto-BHC -0.82
Oelto-BHC -0.33
0ieldrin -0.038
ON 1ND-9URUNG1
Endrin Ketone -0.32
Gommo-BHC (lindone)-1.8
LEGEND
• MONITORING WELL
CONCENTRATIONS IN ug/L
0 50 100
Appro~. $col, 111 Fut
Alpho-BHC -1.7
Beto-BHC -0.19 Oello-BHC -0.16
Endrin Ketone -0.093
Comma-BHC (lindone)-2.2
SOURCE, EPA SITE I..IAP (DH1ElJH) , PHASE II Rl REPORT FIGURE 1 -4
CONCENTRATIONS IN GROUNDWATER
PHASE I RI 1991
PESTICIDE
OR.AWN B'I'. J.C.
FCX STATESVILLE
STATESVILLE, NORTH CAROLINA
Beto-BHC -0.093
Oieldrin -0.037
Endrin -0.061
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NORTH
1 1 1-Trichloroethone -13J
1 '1 '_ Oichloroethone -13J
1 '1-0ichloroethene -9.4J
ch1oroform -4. IJ
Chloromethone -2.9
cls-1,2-Dichloroethene -42
Tetrochloroelhy~ne -170
Trichloroethyene -5.3J
Trichlorotrifluoroethone -60JN
Chloroform -1. 7J
Corban Telroch!oride -4.2J
Trichlorofluoromethone -99
Bromidlchloromelhone -1.4J
Chloroform -10.0
(m-and/or p-) xylene -8.2J
1 1-0ichloroethone -19J
1' 1 Dichloroethyene - 2 IJ
cis-1,2-Dichloroethone -20J
Tetrachloroethyene -230
Chloroform -0.74AJ
1,1,1-Trichloroethone -
1 1 1-Trichloroethone -1.1AJ
1 • 1 :_Oichloroethone - 1 JJ
chioroform -4.2AJ
Tetrochlo,:oethy!ene -20A
Trichloroelhyene -0.8AJ8
Chloroform -3.9J
1, 1-Dichloroelhone - 1 SJ
1,1-0ichloroethene -29
cls-1,2-Dichloroelhene -13J
letrochloroethyene --110
lrichloroethyene -4.0J
1 1 1-Trichloroelhone -7.4J
1: 1 :_Dichloroelhone - 1 JJ
LEGEND
• MONJTORJNG WELL
CONCENTRATIONS IN ug/L
" '"
Approx. S<:olt in Fut
1, l-Dichloroethene -7.3
cls-1.2-Dichloroethene -20
Telrochloroethyene -52
1 1 1-Trichloroelhone -7.4J
1°1:_Dichloroethone -13J
1: 1 Dichloroethyene -7.JJ
cls-1,2-Dichloroe\hene -20
letrochloroethyene - I 10
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Burlington Industries. Specifically, PCE was detected in a seep sample (FS-408) collected at
the head of a stream at a concentration similar to that observed in samples from on-site
monitoring wells. These results indicated a significant groundwater contamination problem,
located not only beneath FCXS, but also apparently beneath the Burlington Industries facility
~(EPA Phase I RI, 1992). Figure 1-6 shows the location of this sample and the analytical results.
1.3.4 Exploratory Boring Results
An extensive effort was put forth to locate the alleged pesticide burial trenches. This effort
consisted of the borings associated with the 27 soil sampling locations within the warehouse, as
well as 9 deep exploratory borings drilled using power-augers. Little or no significant material
was found to indicate the presence of buried pesticide material, either in bags or glass
containers.
1.4 SCOPE OF TIIE PHASE II RI
Phase II of the FCXS RI was primarily an expanded investigation of groundwater quality and
alleged trench location. Existing, on-site permanent monitoring wells and a network of 12
temporary monitoring wells, located both on-site and off-site, were sampled to provide further
groundwater characterization. Twenty to 25 borings were drilled through the warehouse floor
in an effort to locate trenches which have been alleged to exist under the warehouse floor.
Because EPA is currently pursuing delineation of the chlorinated solvent plume with Burlington
Industries, the Phase II groundwater sampling program was designed primarily to evaluate the
extent of pesticide contamination. Samples for purgeable organic compound analyses were also
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SURFACE
FIGURE 1-6
WATER SAMPLING LOCATIONS
FCX-STATESVILLE
CAROLINA STATESVILLS~AlE l~Q~TH
! 0 J MIL[ ieee======'l========iaaee==============
I ooos==so===' oooieeeeeeeee'iiooo==='=OOOE==•eeoooc:===5000E==iii6000c==~'OOOi rEET
gL'.:::'.S:0:U:R::CE:::S::T::A:TE:S:V:IL:L::E::W:E:S::T,~=N=.C=.=(=19::6:9:)====C=O=N=T=O=U=R=l=N=T=E=R=V=A=L=l=O=F=E=E=T===================-
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
surface water. Presently, the most highly contaminated soils are covered by paved areas and
are therefore unavailable for surface water or wind transport. It is likely that further I contaminant transport via soils erosion will be insignificant.
I -The soil permeability, or hydraulic conductivity, controls the amount of groundwater recharge,
surface water runoff and percolation, and rate of contaminant migration through the saturated I zone. At FCXS, the calculated hydraulic conductivity in the saprolite is approximately 1.62 x
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J0·6 ft/sec, which is indicative of a relatively low permeability unit. The depth to the water table
ranges from about 25 to 28 feet. This thickness of the unsaturated zone should allow for
substantial soil immobilization of many of the site-related contaminants.
FCXS is located in a hilltop topographic setting. Such hilltop topographic locations are
characteristically groundwater recharge zones. In groundwater recharge zones, groundwater
flow usually has a downward component and the migration of contaminants into deeper parts of
an aquifer may be enhanced in such areas. Water quality data suggest that this is the case at
FCXS.
Measurements made at the site indicate that the hydraulic conductivity of the saprolite
(weathered bedrock) is relatively low. The bedrock hydraulic conductivity is probably highly
variable, with limited zones of high or moderate permeability along rock fractures, separated by
substantial interfracture areas of extremely low or no permeability. The hydraulic conductivity
contrast between the bedrock and saprolite may also cause groundwater to flow downward from
the saprolite into the bedrock.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
The hydraulic gradient appears to steepen toward the south and east. The variations in the
hydraulic gradient suggest that the site is near a groundwater divide.
The high soil clay content reduces the mobility of both organic compounds and inorganic I ~substances. In bedrock, fracture flow predominates, favoring increased contaminant mobility
in the bedrock (EPA Phase II RI, 1992).
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1.5.2 Contamination Overview
1.5.2.1 Pesticides
Soil pesticide contamination has primarily been detected in on-site soils less than 3 feet deep.
However, DDT was detected below the FCXS building at a concentration of 3,100 µglkg at a
depth of 6 to 6.5 feet (FS-318), and at 62 µg/kg at the 12 to 13 foot bgs interval (FS-307).
Lindane, other BHC compounds, and endrin ketone (a degradation product of endrin) have been
found most frequently and in the highest concentrations in groundwater samples. With the
exception of one detection of lindane in an off-site monitoring well, no other pesticides have
been found in groundwater outside the site boundary. Low-level sediment and surface water
pesticide contamination has also been detected at and near FCXS. Figure 1-7 shows the
approximate extent of the pesticide contaminant plume at the time of the Phase II RI. Figure
1-8 shows concentrations of PCE detected during Phase II RI activities.
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// • MONITORING WELL
/ 0 TEMPORARY MONITORING WELL
I I
t I-ESTIMATED DETECTION BOUNDARY
• • • • AREA OF HIGHEST
CONCENTRATIONS
o, SOURCE: EPA SITE 1.4.A.P (DH\(1347) , PHASE U RI REPORT +,1-----------------------------------1 0 0 v v 0
""l DRAWN BY. J.C.
FIGURE 1 - 7
OVERALL DISTRIBUTION OF PESTICIDES
IN GROUNDWATER PHASE II RI, 1992
FCX -STATESVILLE
STATESVILLE, NORTH CAROLINA
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/ • MONITORING WELL
t f O TEMPORARY MONITORING WELL
LEGEND
I I ~ AREA OF HIGHEST I I ~ CONCENTRATIONS
--> 1 Oug/l TETRACHLOROETHENE
- - - -DETECT BOUNDARY
';'1-------------------------------------g FIGURE 1 -8
SOURCE: EPA SITE MAP (DH1E1347), PHASE II RI REPORT
::: TETRACHLOROETHENE DISTRIBUTION 0
N . DRAWN BY. J.C.
IN GROUNDWATER OVERBURDEN WELLS
PHASE II -1992
FCX -STATESVILLE
STATESVILLE, NORTH CAROLINA
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
1.5.2.2 Dioxin/Furan Analyses
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
During the Phase II RI, five samples, including one duplicate, were analyzed for dioxin/furan
compounds. The samples from locations FS-307-SLA and FS-318-SLA, both located beneath
-the buiiding, contained the highest concentrations and greatest numbers of these compounds.
At location FS-307, where sampling was conducted at depths of0"-12" and 60"-72", it appears
that dioxin/furan concentrations are greatly reduced with depth. The toxicity equivalent quotient
(TEQ) was reduced from an estimated 400 ng/kg for surface sample FS-307-SLA to 0.16 ng/kg
from sample FS-307-SLB, collected from a depth of six feet.
1.5.2.3 Other Organic Compounds
A variety of semivolatile organic compounds (SVOes) and volatile organics have also been
detected in soil, groundwater, surface water, and sediment in and around Fexs. The highest
concentrations of SVOes have generally been detected in on-site soil samples from the surface
to 3 feet deep. Pentachlorophenol (PCP) was detected at a concentration of 11,000,000 µg/kg
(I.I%) in sample FS-318, collected 3 feet below the building during the Phase II RI. Low-level
SVOC contamination has been found in other media.
voes have generally been found in soils in concentrations of less than IO ug/kg and are mostly
present in soil samples from less than 3 feet deep. Soil VOCs are primarily trichloroethene
(TCE) and PCE. Groundwater samples indicated contamination by voes in excess of the
Federal Maximum Contaminant Levels (MeLs) and the North Carolina Drinking Water
Standards, both beneath the site and in a plume extending downgradient of the site. The
distribution of the chlorinated VOCs in soils, groundwater, sediment, and surface water samples
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
indicates that some of the VOC contamination may have originated from an off-site source to
the north of the FCXS property.
1.5.2.4 Metals
Some groundwater samples also contain metals in excess of Federal or state groundwater or
drinking water quality standards. According to the Phase II RI (EPA, 1992) these metals
concentrations do not appear to be directly site-related.
1.5.3 Contaminant Migration Through Soil
1.5.3.1 Pesticides
Soil transport modeling for pesticides (EPA Phase II RI, I 992) indicated that only
pentachlorophenol and lindane have potentially begun leaching to groundwater through recharge
from the surface. With the possible exception of pentachlorophenol (which has not been
detected in groundwater samples), the projected groundwater concentrations of all the other
pesticides from the modeling conducted in the Phase II RI are much less than their observed
groundwater concentrations.
Even if there is substantial soil remediation, the potential short-term pesticide concentration in
recharge water will most likely be much greater if the impervious cover currently on the site is
removed.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
indicates that some of the VOC contamination may have originated from an off-site source to
the north of the FCXS property.
1.5.2.4 Metals
Some groundwater samples also contain metals in excess of Federal or state groundwater or
drinking water quality standards. According to the Phase II RI (EPA, 1992) these metals
concentrations do not appear to be directly site-related.
1.5.3 Contaminant Migration Through Soil
1.5.3.1 Pesticides
Soil transport modeling for pesticides (EPA Phase II RI, 1992) indicated that only
pentachlorophenol and lindane have potentially begun leaching to groundwater through recharge
from the surface. With the possible exception of pentachlorophenol (which has not been
detected in groundwater samples), the projected groundwater concentrations of all the other
pesticides from the modeling conducted in the Phase II RI are much' less than their observed
groundwater concentrations.
Even if there is substantial soil remediation, the potential short-term pesticide concentration in
recharge water will most likely be much greater if the impervious cover currently on the site is
removed.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Four soil samples (plus one duplicate) for dioxin/furan compounds were collected from beneath
the building foundation. The three samples collected from depths of less than two feet contained
toxicity equivalent quotients (TEQs) of between 300 and 600 nanograms per kilogram (ng/kg).
The deeper sample, collected from between 5 and 6 feet below the foundation, contained a much
lower TEQ concentration (0. I 6 ng/kg). Dioxin and furan concentrations were highest near the
surface, due to their low mobility in soil.
1.5.3.2 Volatile Organic Compounds
The results of soil transport modeling show that, potentially, the TeE, PeE, and related
contaminants detected in groundwater beneath the site may have been leached from soils along
the northern side of the site at some tiine in the past. It is therefore possible that some of the
voe contamination now detected in groundwater beneath the site is the result of past leaching
of voe contaminated soils. The location of TeE and PeE contaminated soils beneath mostly
impervious areas suggests that present soil leaching of these contaminants from FeXS is likely
to be insignificant.
1.5.3.3 Metals
There is no indication that metals detected in groundwater are directly site-related. However,
only limited analysis of the leaching of metals was possible with the given data.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
1.5.4 Contaminant Migration Through Groundwater
1.5.4.1 Pesticides
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
In the saprolite, pesticides in groundwater are restricted to the FCXS property, with the
exception of one detection of lindane. Lindane is one of the most mobile pesticides, and would
therefore be expected to migrate farther than the other pesticides; however, the presence of
lindane in the off-site well is difficult to explain. If the estimated movement of lindane in the
saprolite is projected to be equal to the groundwater velocity, it would take over 100 years for
lindane to move through the saprolite from the closest area of lindane groundwater contamination
on the site to the off-site well. Also, the well is not directly downgradient of areas of pesticide
contamination at the site.
The modeled potential extent of pesticide contaminant plumes in the saprolite based on the
observed lindane migration ranged from only a few feet from the source area for DDT and DDD
to over 100 feet from the source area for the most mobile pesticides. Contaminant migration
rates in the bedrock are projected to be faster than contaminant migration rates in the saprolite.
Only the more mobile pesticides (BHCs and endrin ketone) have been found in samples from
any bedrock wells, indicating that the vertical movement of the other, less mobile pesticides
through the saprolite has not yet been detected in the bedrock groundwater.
1.5.4.2 Volatile Organic Compounds
Groundwater transport of VOCs is also difficult to quantify or model with the available data.
In the saprolite, part of the chlorinated VOC plume extends at least as far downgradient as a
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
well which is over 200 feet downgradient from any possible source area on the FCXS property
(See Figure 1-8), and is over 500 feet downgradient from a suspected upgradient source area.
The presence of PCB and TCB at this location cannot be explained by the average groundwater
velocity in the saprolite. It is likely that there are some zones of considerably higher hydraulic
conductivity in the saprolite, which could transmit contaminants much faster than is implied by
the average groundwater velocity. Another possibility is that the downgradient well was located
in an area where pumping the well could cause upward migration of VOCs from the underlying
bedrock. The bedrock appears to contain zones of substantially higher hydraulic conductivity
than the saprolite.
Based on current contaminant concentrations and model projected concentrations, contaminant
concentrations for future time periods of 10 and 25 years were estimated. This analysis
indicated that the chlorinated VOC plume front could move a substantial distance downgradient
in the saprolite aquifer over the next 25 years. The 0.005 mg/L total VOC contour may extend
another 350 feet downgradient after 25 years.
VOC contaminant transport in the bedrock was not modeled because of the lack of suitable
monitoring points for comparison of observed to modeled concentrations. Contaminant transport
in the bedrock is expected to be more rapid than in the saprolite aquifer. The estimated
concentration of 0.53 ug/L of PCB in a surface water sample downgradient of the site suggests
that the leading edge of the bedrock VOC plume has already reached this surface water
discharge point.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
1.5.4.3 Metals
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Metal transport in groundwater cannot be predicted with the available data. Sampling data
suggest that metals concentrations detected in the groundwater samples reflect either localized
-equilibrium conditions between solid and aqueous phase metals, or that the observed saprolite
well sample metals concentrations reflect influences of suspended solids which were withdrawn
with the samples. Significant movement of any metals plumes through the groundwater is
considered unlikely (EPA Phase II RI, 1993).
1.5.5 Chemical Characterization of Surface Water and Sediment
Surface water samples collected downstream of FCXS have metals concentrations which are
similar to background concentrations. The potential inorganic contaminants of concern in
surface water were found in concentrations significantly higher in surface water samples
collected in areas which are not downstream of FCXS than in the surface water background
sample.
The highest concentrations of volatile organics were detected in surface water samples collected
in areas which are not downstream of the site. Low-level PCE contamination detected in a
surface water sample downstream of the site may be site related. This contamination probably
does not persist for any distance downstream of the sample location because of the volatility of
the compound; however, surface samples have not been collected further downstream to date.
Several pesticides were detected in low concentrations (less than 0.05 ug/L) in one surface water
sample. These pesticides were also found in a sediment sample collected at this location. The
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
ratio of sediment to surface water concentrations indicates that the surface water contamination
at this location may be due to the partitioning of low levels of the pesticides into the water from
contaminated sediment at this location. Pesticide contaminant transport to the area of this
sample was most likely via surface-water nmoff of contaminated sediment which was deposited
-in this location. Transport of the dissolved pesticides further downstream is expected to be
minimal because of the high affinity of the pesticides for immobilization on sediment; however,
if sediment is already contaminated further downstream by comparable levels of pesticides,
similar surface water pesticide concentrations may be expected there.
Sampling of sediment near and around FCXS indicates that only limited transport of sediment
contaminated by site-related contaminants is occurring or has occurred. Since the majority of
contaminated soil is under buildings and pavement, further pesticide erosion and downstream
deposition of sediment is unlikely to be significant.
1.6 RESULTS OF THE SUPPLEMENTAL EPA SAMPLING
In July 1993, additional soil samples were collected by EPA Region IV Hazardous Waste Section
personnel from the FCXS site. The purpose of these samples was to "further delineate the
horizontal and vertical contaminant patterns of selected pesticides and pentachlorophenol, and
to provide additional characterization of dioxin/furan concentrations and distributions across the
site." Sixteen locations were sampled and analyzed for extractable organic compounds and
pesticides/PCBs. Nineteen locations were sampled and analyzed for dioxins/furans.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
1.6.1 Extractable Or,:anics and Pesticides/PCBs
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 1
Revision: 1
Date: June 1994
Pentachlorophenol, the primary extractable organic of concern in this study, was con finned in
only one location, FS-307, beneath the building at a depth of 24 ft bgs. Other extractable
organics were detected in the deep sample collected from location FS-226; however, these data
were rejected based on quality control problems.
Pesticides were detected in both samples collected at locations FS-226, FS-302, FS-307, FS-317,
and FS-324. The presence and concentrations of these pesticides confonns with the historical
layout of the buildings at the property.
1.6.2 Dioxins/Furans
Dioxin and/or furan compounds were detected in all soil samples except the deep samples
collected from locations FS-262 and FS-315. The most common compound detected, and at the
highest concentrations, was octachlorodibenzodioxin. No sample analyzed for dioxin was found
to have a toxicity equivalent quotient (TEQ) greater than 1,000 ng/kg (1 µglkg). Approximately
85 percent of the samples showed TEQ values less than 10 ng/kg (0.01 µg/kg).
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
SECTION 2
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
This section identifies, defines, and evaluates Federal, state, and local regulations as they apply
to the FCXS site, Operable Unit 2 (soils).
2.1 INTRODUCTION
The Superfund Amendments and Reauthorization Act (SARA) of 1986 and the NCP, revised
March 8, 1990 (40 CFR 300), requires that the development and evaluation of remedial actions
under the Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA, commonly known as Superfund) include a comparison of alternative site responses
to applicable or relevant and appropriate Federal and state environmental and public health
requirements (ARARs).
In accordance with the requirements of the NCP, the remedial action selected must meet all
ARARs unless a waiver from specific requirements can be granted by the EPA or by the State.
According to SARA Section 121, CERCLA Section 121 (d)(4), a waiver may be granted for one
or more of the following conditions:
•
•
•
The remedial action under consideration is only an interim remedy and is not the
final or permanent remedy selected for the site.
Compliance with the ARARs would create greater risks to public health and the
environment than benefits.
Compliance with such standards is technically impractical.
NOR/G:\HOME\ WP\04400\011 \FSBAM-2.WP 2-1
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
•
•
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
A different remedy exists that provides protection to public health and the
environment equivalent to the preferred cleanup standard.
A more stringent state standard which would otherwise be applicable has not been
consistently applied to other sites in the state.
Compliance with an applicable state requirement would effectively result in the
statewide prohibition of land disposal of hazardous substances.
The cost of the remedy is too expensive, considering the other demands on the
fund.
2.2 IDENTIFICATION OJ? ARARs
Identification of ARARs must be performed on a site-specific basis. The NCP and SARA do I not provide across-the-board standards for evaluating whether a particular remedial action will
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produce an adequate remedy at a particular site. Rather, the process recognizes that each site
will have unique characteristics that must be evaluated and compared to those applicable and
relevant requirements that apply under the given circumstances. ARARs are defined as follows:
•
•
Applicable requirements are those cleanup standards, standards of control, and
other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal, state, or local law that specifically address a
hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance found at a CERCLA site.
Relevant and appropriate requirements are those cleanup standards, standards of
control, and other substantive environmental protection requirements, criteria, or
limitations promulgated under Federal, .state, or local law that, while not
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
"applicable" to a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at a CERCLA site.
-The FCXS site has been classified as a National Priorities List (NPL) site under
CERCLA/SARA. For remedial actions performed under SARA, permits for compliance with
regulations for on-site remedial actions are not required; however, CERCLA and SARA do
require that the selected alternative meet regulatory standards or performance levels where
possible.
ARARs can be divided into the following categories:
•
•
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Chemical-specific requirements: Health-or risk-based concentration limits or
ranges in various environmental media for specific hazardous substances,
pollutants, or contaminants. These limits may take the fonn of action levels or
discharge levels.
Location-specific requirements: Restrictions on activities that are based on the
characteristics of a site or its immediate environment. An example would be
restrictions on wetlands development.
Action-specific requirements: Controls or restrictions on particular types of
activities such as hazardous waste management or wastewater treatment. An
example would be RCRA incineration standards. Such requirements are triggered
by the particular remedial action selected.
NOR/G:\HOME\ WP\04400\011 \FSBRM-2.WP 2-3
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Based on discussions with U.S. EPA-Region IV and NCDEHNR and review of appropriate
guidance documents (EPA 1988c, EPA 1989c), Federal, state, and local ARAR sources were
identified as listed in Table 2-1.
An evaluation of the potential Federal and State ARARs that were considered is presented in
Tables 2-2 and 2-3, respectively, summarizing the following information:
•
•
•
•
•
Standard, requirement, criteria, or limitation
Regulatory citation
Description
Applicability of the ARAR (yes or no)
Justification comments
I Many of the requirements relating to groundwater and surface water should be ARARs only if
water is generated and discharged as part of the remedial action.
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The potential Federal and state ARARs are discussed in the following subsections.
2.3 FEDERAL ARARs
2.3.1 Resource Conservation and Recovery Act (RCRA)
RCRA (42 USCA 6901 et seq.) mandated that EPA:
• Establish a comprehensive regulatory program to control and manage hazardous
waste (Subtitle C).
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
FEDERAL
STATE
Table 2-1
Summary of ARAR Sources Evaluated
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CW A)
Safe Drinking Water Act (SDW A)
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
Haz.ardous Materials Transportation Act
Protection of Wetlands (Executive Order 11990)
Floodplain Management (Executive Order 11988)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Regulations Protecting Landmarks, Historical, and Archeological Sites
Endangered Species Act
Fish and Wildlife Coordination Act
EPA OSWER Soil Screening Levels
North Carolina Hazardous Waste Management Rules and
Solid Waste Management Law
North Carolina Water and Air Resources Act
North Carolina Water Pollution Control Regulations
North Carolina Drinking Water Act
North Carolina Drinking Water and Groundwater Standards
North Carolina Surface Water Quality Standards
North Carolina Air Pollution Control Regulations
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Table 2-2
Analysis of Potential Federal ARARs
Standard, Requirement, Regulatory
Criteria, or Limitation Citation Description
Resource Conservation and Recovery Act
Chemical-Specific ARARs
Identification and Listing of 40 CFR Part 26 J Defines those solid wastes which are subject to
Hazardous Waste regulation as hazardous waste under 40 CFR
Parts 262-270.
Location-Specific ARARs
Seismic considerations 40 CFR 264. JS(a) Restricts location of TSO facilities within 200 ft
of a fault that has had a displacement within
Holocene time.
Floodplains 40 CFR 264. lS(b) Requires TSO facility located within a JOO-year
flood plain to be designed, constructed,
operated, and maintained to prevent washout of
any hazardous wastes by a I 00-year flood.
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Potential
ARAR
Yes
No
No
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to remedial
actions involving solid waste (soil)
removal in the identification of wastes
and application of other action specific
ARARs.
No known faults within or in the
vicinity of the site.
The site or the remedial actions are not
located in the JOO-year flood plain.
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---- ---- - - --- - - -
This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Resource Conservation and Recovery Act (continued)
Action-Specific ARARs
Requirements for hazardous 40 CFR Part 262
waste generators
Requirements for 40 CFR Part 263
transporters of hazardous
waste
Requirements for hazardous 40 CFR Parts 264
waste treatment, storage, and 265
and disposal (TSD)
facilities, including
landfilling, capping,
incineration, thermal
treatment, and
chemical/physical/biological
treatment.
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Establishes standards for generators of hazardous
wastes.
Establishes standards which apply to transporters
of hazardous waste within the United States if
the transportation requires a manifest under 40
CFR Part 262.
Establishes minimum national standards which
define the acceptable management of hazardous
wastes for owners and operators of facilities
which treat, store, or dispose of hazardous
wastes.
2-7
Potential
ARAR
Yes
Yes
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to remedial
actions involving removal of hazardous
waste.
Potentially applicable to remedial
actions involving removal of hazardous
waste.
Potentially applicable to remedial
actions involving removal of hazardous
waste and subsequent treatment of such
wastes.
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---- ----- -- - - ----
This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Land Disposal Restrictions 40 CFR Part 268
Clean Water Act (CWA)
Chemical-Specific ARARs
Water quality criteria CWA Part 303
40 CFR Part 131
Action-Specific ARARs
National Pollutant Discharge CWA Part 402
Elimination System 40 CFR Part 125
(NPDES) requirements
Effluent guidelines and 40 CFR Part 40 I
standards for the point
source category
National pretreatment CWA Part 307(b)
standard for indirect 40 CFR Part 403
discharge to a POTW
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Identifies haz.ardous wastes that are restricted
from land disposal
Establishes water quality criteria based on the
protection of human health and aquatic life.
Requires pennit for effluent discharge from any
point source into surface waters of the United
States.
Requires specific effluent characteristics for
discharge through NPDES system.
Establishes standards to control pollutants which
pass through or interfere with treatment
processes in public treatment works which may
contaminate sewage sludge.
2-8
Potential
ARAR
Yes
Yes
Yes
No
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to remedial
actions involving removal of haz.ardous
wastes (e.g., soil excavation)
Potentially applicable to remedial
actions involving discharge of water to
a surface water body.
Potentially applicable to remedial
actions involving discharges to surface
waters.
No categorical standards established for
hazardous waste sites.
Potentially applicable to discharge of
water into local POTW.
-
----- ----- --- ------
This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Technology-based effluent CWA Part 30l(b)
limitations
Safe Drinking Water Act (SDWA)
Chemical-Specific ARARs
National Primary Drinking 40 CFR Part 141
Water Standards
National Secondary 40 CFR Part 143
Drinking Water Standards
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Establishes guidelines to determine effluent
standards based on the best available technology
(BA 1) economically achievable.
Establishes health-based enforceable standards
for public water systems (maximum contaminant
levels (MCLs)).
Establishes aesthetic-based, non-enforceable
guidelines for public water systems (secondary
maximum contaminant levels (SMCLs)).
2-9
Potential
ARAR
Yes
Yes
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to aqueous
effluent from remedial processes.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
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--- ---- - - - --- -- --
This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Clean Air Act (CAA)
Chemical-Specific ARARs
National Ambient Air 40 CFR Part 50
Quality Standards (N AA QS)
National Emission Standards 40 CFR Part 61
for Hazardous Air
Pollutants (NESHAP)
Occupational Safety and Health Act
Action-Specific ARARs
Safety of workers 29 USC 651-678
29 CFR 1910
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Establishes ambient air quality standards for
classes of pollutants -carbon monoxide,
hydrocarbons, lead, nitrogen dioxide, particulate
matter, ozone, and sulfur oxides. Standards do
not apply directly to source-specific emissions,
but are ambient concentration limitations.
Establishes emission standards for seven
contaminants -benzene, mercury, arsenic,
asbestos, beryllium, vinyl chloride, and
radionuclides.
Regulates workers' health and safety.
2-10
Potential
ARAR
No
No
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
. Only "major sources" (emissions
exceeding 100-250 tons per year of
regulated pollutants) are subject to
N AAQS attainment requirements.
Not applicable to the site as benzene
and vinyl chloride are not produced as
a result of manufacturing operations.
Applicable to remedial actions at the
site.
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-- - ---------- ----
This document was prepared by Ray F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Hazardous Materials Transportation Act
Action-Specific ARARs
Hazardous Materials 49 use 1801-1813
Transportation Regulations 49 CFR 107, 171-
177
Protection of Wetlands (Executive Order 11990)
Location-Specific ARARs
Regulations to protect Executive -Order
wetlands No. 11990
49 CFR 6.302(a)
and Appendix A.
Floodplain Management (Executive Order 11988)
Location-Specific ARARs
Regulations to protect Executive Order
floodplains No. 11988
40 CFR 6,
Appendix A
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Regulates transportation of Department to
Transportation (DO1)-defined hazardous
materials.
Requires consideration of the adverse impacts
associated with the destruction or loss of
wetlands· and to avoid support of new
construction in wetlands if a practical alternative
exists.
Requires evaluation of the potential effects of
actions which may be taken in a floodplain to
avoid the adverse impacts associated with direct
and indirect development of a floodplain.
2-11
Potential
ARAR
Yes
No
No
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Applicable to remedial action involving
transportation of DOT-defined
hazardous materials off-site.
Site is not located in a wetland area.
Site is not located in the 100-year
floodplain.
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---- -- - -------- --
This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Regulations Protecting Landmarks, Historical, and Archeological Sites
Location-Specific ARARs
National natural landmarks Historic Sites Act Establishes regulations to protect national natural
of 1935, 16 use landmarks during remedial actions.
461,
40 CFR 6.301(a)
Historic, architectural, National Historic Establishes regulations to protect historic,
archeological, and cultural Preservation Act of architectural,· archeological, and cultural sites
sites 1966, 16 use during remedial actions.
470, 36 CFR 800,
Executive order
11593
40 CFR 6.30l(b)
Historic, prehistoric and Archeological Establishes regulations to protect historic,
archeological data Preservation Act of prehistoric, and archeological data during
1974, 16 USC 469 remedial actions.
et seq.
Executive Order
11593
40 CFR 6.30l(c)
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Potential
ARAR
No
No
No
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Site is not located in an area with
natural landmarks.
Site is not located in an area with
historic, architectural, archeological or
cultural sites.
Site is not located in an area with
prehistoric or archeological data.
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--- -- ----- ------·-
This document was prepared by Roy F. Weston, Inc., expressly_for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
Feasibility Study Report
Standard, Requirement, Regulatory
Criteria, or Limitation Citation
Endangered Species Act
Action-Specific ARARs
Protection of endangered 16 use 1531
species 50 CFR Part 200
50 CFR Part 402
Fish and Wildlife Coordination Act
Action-Specific ARARs
Protection of fish and 16 use 661-666
wildlife due to any
modifications of water
bodies.
EPA OSWER Soil Screening Levels
Chemical concentrations in None
soil for 30 contaminants (Draft version)
which, if identified, would
warrant further investigation
of a site.
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Table 2-2 (Continued)
Analysis of Potential Federal ARARs
Description
Requires action to conserve endangered species
and/or critical habitats upon which endangered
species depend.
Requires adequate provision for protection of
fish and wildlife resources when any
modification of any stream or other water body
is proposed.
Lists concentrations of 30 soil contaminants
commonly found at Superfund sites that are to be
used as screening tools in ideritifying soils of
potential concern and eliminating clean soils
from further consideration.
2-13
Potential
ARAR
Yes
Yes
Yes
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable as endangered
and threatened species have been
identified as candidate species in Iredell
Onslow County.
Potentially applicable if the remedial
action involves discharge of treated
water to New River.
Potentially relevant and appropriate to
remedial actions involving soil
contamination.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Table 2-3
Analysis of Potential State of North Carolina ARARs
Standard, Requirement,
Criteria, or Limitation Citation Description
North Carolina Waste Management Rules and Solid Waste Management Law
Chemical-Specific ARARs
Identification and listing of 15 A NCAC Defines. those solid wastes which are subject to
hazardous waste. 13 A.0006 state regulation and as a hazardous waste.
Consistent with corresponding federal standards
( characteristic and listed hazardous waste
designations).
North Carolina Water and Air Resources Act
Action-Specific ARARs
Laws to achieve and to General Statutes, State equivalent of the Federal CW A and CAA
maintain a total environment Chapter 143 Article
with superior quality. 21B
North Carolina Drinking Water Act
Action-Specific ARARs
Regulations on drinking water General Statutes Establishes criteria for protection of state public
Chapter 130A, water supplies.
Article 10
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Potential
ARAR
Yes
Yes
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to remedial
actions involving solid waste (soil)
removal.
Potentially applicable for remedial
action involving discharge of water and
air emissions.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
---- - -------.. --
This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Table 2-3 (Continued)
Analysis of Potential State of North Carolina ARARs
Standard, Requirement,
Criteria, or Limitation Citation Description
North Carolina Water Pollution Control Regulations
Action-Specific ARARs
Requirements for NCAC Title 15 Requires permit for discharge of effluent from
wastewater discharge to Chapter 2, point sources into surface waters. State-level
surface water Subchapter 2H version of federal NPDES program.
Wastewater Treatment NCAC Title 15, Establishes basic wastewater treatment
Requirements Chapter 2, requirements for effluent discharge.
Subchapter 2H.0100
North Carolina Drinking Water and Groundwater Standards
Chemical-Specific ARARs
Groundwater Classifications NCAC Title 15, Establishes groundwater and drinking water
and Standards Chapter 2, standards based on the usage.
Subchapter 2L.0200
and 0.0201
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Potential
ARAR
Yes
Yes
Yes
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to remedial
actions involving point source
discharges to surface waters.
Potentially applicable to remedial
actions involving point source
discharges.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
----- - ----- - -----
This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Standard, Requirement,
Criteria, or Limitation Citation
North Carolina Surface Water Quality Standards
Chemical-Specific ARARs
Classification and water NCAC Title 15A,
quaiity standards applicable Chapter 2,
to surface water Subchapters 2L.0IOO
and 2L.0200
Technology-based effluent NCAC Title 15A,
limitations Subchapter 2B.0400
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Table 2-3 (Continued)
Analysis of Potential State of North Carolina ARARs
Potential
Description ARAR
Establishes a series of classifications and water Yes
quality standards for surface waters.
Establishes guidelines for effluent limitations Yes
based on BAT economically achievable.
2-16
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Justification
Comments
Potentially applicable to discharge of
water to a surface water body.
Potentially applicable to discharge of
water.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Promulgate regulations containing guidelines to assist in the development and
implementation of state nonhazardous solid waste management plans (Subtitle D).
In general, RCRA regulations apply to the management of RCRA hazardous wastes and RCRA
waste management (treatment, storage, and disposal (TSO)) facilities subsequent to the effective
date of RCRA regulations. Wastes that are removed from closed facilities may be subject to
RCRA waste classification and must meet RCRA standards with respect to proper management,
treatment, and disposal of the wastes.
Regulations promulgated under RCRA generally provide the basis for management of hazardous
waste and establish technology-based requirements for hazardous waste facilities. RCRA facility
design standards may also be consulted for other wastes containing significant concentrations of
hazardous constituents.
2.3.1.1 Chemical-Specific ARARs
Hazardous waste identification under RCRA is detailed within 40 CFR 261. The two basic
classifications of RCRA hazardous wastes are:
• Listed hazardous wastes (defined under Subpart D of 40 CFR 261), which involve
specific identification of the following regulatory listings:
Hazardous Waste from Nonspecific Sources (F-series wastes listed under
40 CFR 261.31).
Hazardous Waste from Specific Sources (K-series wastes listed under 40
CFR 261.32).
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section:. 2
Revision: 1
Date: June 1994
Commercial Chemical Products (P-and U-series wastes listed under 40
CFR 261.33).
Characteristic hazardous wastes (defined under Subpart C of 40 CFR 261), which
involve evaluation of the following general waste characteristics:
Ignitability (D001 waste)
Corrosivity (D002 waste)
Reactivity (D003 waste)
Toxicity (D004 -D043 wastes)
If a waste is not a listed hazardous waste, it may still be a hazardous waste if it meets any of
the four characteristics cited above; these characteristics can be determined by specific tests cited
in the regulations. Alternatively, if knowledge of the source or properties of a waste indicates
that it may have any of these characteristics, the material can be declared hazardous without
being tested, and would remain classified as a hazardous waste even after treatment unless all
of the contaminants have been removed or the material is "delisted".
Contaminated soils at FCXS have not been shown to be either listed or characteristic hazardous
wastes, since the alleged pesticide burial pit has not been located and the soil has not been tested
using the Toxicity Characteristic Leaching Procedure (TCLP). Given the existing soils data, it
is unlikely that the soil would fail the TCLP, since only Endrin and Lindane could possibly I exceed the TCLP limits even if all the contaminants leached out of the soil and into the leachate.
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Therefore, the RCRA hazardous waste regulations discussed herein may not be applicable. EPA
intends to conduct TCLP tests on a representative number of soil samples during the remedial
design phase to determine if the soil is a RCRA-characteristic hazardous waste.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
2.3.1.2 Location-Specific Requirements
Location-specific ARARs within RCRA include the location standards detailed under
40 CPR 264.18. These standards potentially apply to the siting of a new on-site TSD unit for
~managing RCRA hazardous wastes generated as part of a remedial alternative.
The location standards are as follows:
•
•
Seismic considerations restrict TSD facilities from within 200 feet of a fault that
has had a displacement within Holocene time. As the site is not located in the
political jurisdictions listed in Appendix VI of 40 CPR 264, the site would be in
compliance with this requirement as per 40 CPR 270.14(b)(l l).
Floodplain considerations require TSD facilities located within a 100-year
floodplain to be designed, constructed, operated, and maintained to prevent the
movement of hazardous waste from the active portion of the facility as a result
of flooding. Since FCXS is not within a 100-year floodplain as established by the
Federal Emergency Management Agency (FEMA), an on-site facility would be
in compliance with this requirement.
2.3.1.3 Action-Specific Requirements
ARARs for management of hazardous waste under RCRA include:
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
• Generator requirements •
• Transporter requirements •
• TSD facility requirements •
• Land Disposal Restrictions •
• Landfill requirements •
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section; 2
Revision: 1
Date: June 1994
Capping requirements
Incineration regulations
Thennal treatment regulations
Chemical, physical, and biological treatment regulations
Waste pile regulations
Each action-specific ARAR is addressed in the following subsections.
Generator Requirements
Generator requirements under RCRA apply to operations that accumulate RCRA-defined I hazardous wastes generated on-site in containers or tanks for less than 90 days prior to transport
to another facility for proper treatment/disposal. Generators that accumulate RCRA hazardous
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waste beyond 90 days operate a RCRA storage facility subject to TSD facility requirements as
discussed below. Generator requirements ( 40 CFR 262) are potential ARARs to the site for
remedial actions involving removal/accumulation of materials qualifying as RCRA hazardous
waste for subsequent off-site treatment/disposal. This regulation may be relevant to FCXS
depending on the technologies to be used in the remedial actions. For example, activated carbon
adsorption produces spent carbon, a potential hazardous waste, which would be transported off-
site for treatment or disposal.
Specific RCRA generator requirements include the following:
•
•
Use of the manifest system (Subpart B) to track hazardous waste shipments .
Pre-transport requirements (Subpart C) including proper packaging, labeling, ·
marking, placarding, and accumulation requirements for containers and/or tanks.
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without the express written permission of EPA
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Recordkeeping and reporting requirements (Subpart D) .
Transporter Requirements
-Because remedial actions considered for the site may include potential transport of RCRA-
defined hazardous waste off-site, RCRA transporter requirements specified under 40 CFR 263
are potential ARARs.
The main provision identified under RCRA transporter requirements is compliance with a
manifest system (Subpart B). Other transportation requirements addressed by DOT are discussed
under Subsection 2.3.6.
Treatment, Storage, and Disposal Facility Requirements
TSD facility requirements under RCRA apply to facilities which treat, dispose, or store (for
greater than 90 days) RCRA hazardous waste. TSD requirements (40 CFR 264) are potential
ARARs to the site for remedial actions involving TSD of on-site materials qualifying as RCRA
hazardous wastes. Specific requirements include:
• General facility standards (Subpart B) including those for waste analysis, security,
inspections, and personnel training.
• Preparedness and prevention standards (Subpart C) addressing facility design and
operation, required equipment, testing and maintenance of required equipment,
communication/alarm systems, and aisle space for container storage.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
•
•
•
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Contingency plan and emergency procedures (Subpart D) .
Manifest system. recordkeeping. and reporting (Subpart E) to track hazardous
waste continuously.
Groundwater monitoring (Subpart F) for new landfill. land treatment, and waste
pile units.
Air emission standards for process vents (Subpart AA) which set standards for
process vents associated with distillation, fractionation, thin-film evaporation,
solvent extraction, or air/steam stripping operations involving RCRA hazardous
wastes with organic concentrations of at least 10 parts per million (ppm) (weight
basis).
Air emission standards for equipment leaks (Subpart BB) which sets standards for
equipment that contains or contacts RCRA hazardous waste with organic
concentrations of at least 10 ppm (weight basis).
TSD regulations are applicable only if the remedial actions include generation of hazardous
waste, for example, spent carbon from carbon absorption process. Efforts should be made
during remediation to keep the storage of hazardous waste to less than 90 days so that the
additional storage requirements are not involved.
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Land Disposal Restrictions
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Land disposal is defined to include, but not be limited to, any placement of a RCRA hazardous
waste in a landfill, surface impoundment, waste pile, injection well, land treatment facility, salt
-dome or salt bed formation, or underground mine or cave. As a result, RCRA land disposal
restrictions would apply at the FCXS site to any RCRA hazardous waste removed and placed
outside of the present area of contamination or sent to an off-site TSD facility. Based on
discussions with EPA, it was concluded that the contaminated soils would exhibit the
characteristic of toxicity and would be considered hazardous wastes. Therefore, land disposal
restriction regulations are considered potential ARARs. TCLP testing on a representative
number samples will be performed during the remedial design.
Land disposal of a RCRA hazardous waste is regulated under 40 CFR 268. As directed under
SARA, EPA must promulgate treatment standards for all hazardous wastes. Established
treatment standards are presented under Subpart D of 40 CFR 268. Wastes that meet these
treatment standards may be directly land disposed. Wastes that do not meet these standards must
be treated to meet the corresponding standard before they are placed in a land disposal unit. The
treatment standards are expressed as either:
• A concentration level to be achieved (performance-based) utilizing any available
technology to meet the standard.
• A specified Best Demonstrated Available Technology (BDA T) that must be used (technology-based).
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Hazardous wastes that do not meet· the treatment standards are prohibited from land disposal
under Subpart C of 40 CFR 268. Furthermore, under Subpart E of 40 CFR 268, the following
prohibitions are placed on storage of such restricted wastes:
• Generators may store such wastes in tanks or containers on-site solely for the
purpose of the accumulation of such quantities of hazardous waste as necessary
to facilitate proper recovery, treatment, or disposal.
• TSD facilities may store such wastes in tanks or containers solely for the purpose
of the accumulation of such quantities of hazardous waste as necessary to
facilitate proper recovery, treatment, or disposal.
Knowledge about the generation of the wastes is necessary to determine whether a waste code
applies. In order to classify contamination in the soil as RCRA-listed hazardous waste, some
evidence of dumping is required .. No evidence of the alJeged pesticide burial pit was found
during the remedial investigation. The soil sample results from the RI have indicated the
contaminated soil resulted from poor housekeeping and does not fall into one of the descriptive
categories in 40 CFR Subpart D. Therefore, the contaminated soil is not classified as an RCRA-
listed hazardous waste.
Landfilling
RCRA applies to hazardous waste activities conducted after the effective date of RCRA
regulations. As such, RCRA landfill requirements do not apply to facilities closed prior to the
enactment of RCRA. However, any RCRA hazardous waste removed and subsequently
landfilled as a RCRA hazardous waste is subject to RCRA landfilling regulations and LDRs.
Landfilling of a RCRA hazardous waste is regulated under 40 CFR 264 and 265, Subpart N.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
These regulations include provisions for the design, operation, monitoring, inspection, and
closure of hazardous waste landfills. Specific performance standards are presented for liners and J leachate collection systems.
I 1n addition to the Subpart N requirements, a groundwater monitoring program to. detect potential
releases from landfills is specified under 40 CFR 264.91 to 264.100 and 265.91 to 265.94.
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Capping
The substantive requirements for capping a RCRA hazardous waste are outlined in the RCRA
landfill regulations, 40 CFR 264 Subpart N and 310 CMR 30. According to EPA guidance
(1988), capping does not constitute disposal; however, the capping requirements set forth in 40
CFR 264 Subpart N are relevant and appropriate to the capping of wastes to a CERCLA site.
Under RCRA, the cap must be designed to:
•
•
•
•
•
Provide long-term minimization of migration of liquids through the capped area .
Function with minimal maintenance .
Promote drainage and minimize erosion .
· Accommodate settling and subsidence .
Have a permeability less than or equal to the permeability of the natural subsoils
present.
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without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
section: 2
Revision: 1
Date: June 1994
In addition, post-closure care and maintenance must be carried out at the capped area for at least
30 years after closure.
Incineration
If incineration 1s considered a remedial action at FCXS, RCRA regulations governing
incineration represent potential ARARs. Incineration of a RCRA hazardous waste is regulated
under 40 CFR 264 and 265, Subpart 0 and 310 CMR 7. These regulations include provisions
for:
• Waste feed analysis (40 CFR 264.341 and 265.341).
• Operating requirements (40 CFR 264.345 and 264.345).
• Monitoring and inspections (40 CFR 264.347 and 265.345).
• Closure with disposal of all hazardous waste and residues, including ash, scrubber
water, and scrubber sludge (40 CFR 264.351 and 265.351).
• Compliance with additional general TSD facility requirements.
In addition, the regulations establish performance standards for incineration (40 CFR 264.342
and 264. 343) that include:
• Achieving a destruction and removal efficiency (DRE) of 99. 99 % for each
principal organic hazardous constituent (POHC) in the waste feed.
• Reducing hydrogen chloride (HCl) emissions to I. 8 kg/hr or 1 % of the HCl in
the stack gas before it enters any pollution control device.
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without the express written permission of EPA. ·
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
• Not releasing particulate matter in excess of 180 mg/m3, corrected for the amount
of oxygen in the stack gas.
The ability to meet these performance standards must be demonstrated during a trial bum period.
Thermal Treatment
If thermal treatment is considered as a remedial action at FCXS, RCRA regulations governing
thennal treatment represent potential ARARs. Thermal treatment of a RCRA hazardous waste
is regulated under 40 CFR 265, Subpart P. These regulations include provisions for the
following items:
•
•
•
•
Operating requirements (40 CFR 265.373)
Waste analysis (40 CFR 265.375)
Monitoring and inspections (40 CFR 265.377)
Closure (40 CFR 265.381)
In addition, the regulations prohibit open burning of hazardous wastes except waste explosives
and selected "F" series wastes (40 CFR 265.382 and 265.383).
Chemical, Physical, and Biological Treatment
The regulations in 40 CFR 265, Subpart Q, potentially apply to remedial actions at FCXS, if
the facility is to treat RCRA hazardous wastes using chemical, physical, or biological methods
other than treatment in tanks, surface impoundments, and land treatment facilities. These
regulations include provisions for:
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
• Operating requirements ( 40 CFR 265,401)
• Waste analysis and trial tests (40 CFR 265,402)
• Inspections ( 40 CFR 265,403)
• Closure (40 CFR 265,404)
In addition, the regulations have special requirements for reactive and incompatible wastes,
Waste Piles
Waste piles are defined under 40 CFR 260, 10 as "any noncontainerized accumulation of solid,
nonflowing hazardous waste that is used for treatment or storage," As remedial actions
involving excavation could occur at FCXS, waste pile regulations are potential ARARs, Waste
piles are regulated under 40 CFR 264 and 265, Subpart L, as well as under LDRs, Subpart L
requirements include:
•
•
•
•
•
•
•
Design and operating requirements ( 40 CFR 264,251 and 265,254)
Waste analysis (40 CFR 265,252)
Monitoring and inspection (40 CFR 264,254)
Containment (40 CFR 265,253)
Closure and post-closure care (40 CFR 264,258 and 265.258)
Special requirements for special wastes (40 CFR 264,256,264.257, 265,256, and
265,257)
Compliance with additional general TSD facility requirements
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
2.3.2 Clean Water Act
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The Clean Water Act (CW A), formerly known as the Water Pollution Control Act
(33 USC 1251 et seq.), mandated that EPA establish regulations to protect the quality of surface
-waters ·across the nation. As such, it can be applied as an ARAR to the site based on the
potential discharge of the water to either surface water or the local publicly owned treatment
works (POTWs).
Under the CW A, two interrelated areas were identified for regulation:
•
•
Establishment: of water quality standards .
Establishment: of effluent standards (discharge limitations) .
Water quality standards represent chemical-specific requirements, while effluent standards are
action-based requirements. Each requirement is addressed separately in this section. No
location-specific requirements were identified.
2.3.2.1 Chemical-Specific Requirements
Under Section 303 of the CW A, the State of North Carolina is mandated to establish a stream
classification system and corresponding set of water quality standards for each classification.
To aid in development of this system, Federal water quality criteria documents have been
published for 65 pollutants listed as toxic under the CW A.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The Federal water quality criteria specified under 40 CFR 131 are generally represented in
categories that are aligned with different surface water use designations. Different water quality
criteria have been developed based upon:
·• Protection of human health, with consideration of two scenarios:
-Water and fish ingestion by humans
-Fish ingestion on! y
• Protection of aquatic life (both freshwater and marine) against acute toxicity and
chronic toxicity effects.
On December 22, 1992, the Federal Register published revised Federal criteria for priority toxic
pollutants. The final mle, "Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; State Compliance," (40 CFR Part 131), is intended to bring all states
into compliance with the requirements of section 303(c)(2)(B) of the CWA. As of Febmary 5,
1993, they became legally enforceable standards except where state standards are more stringent.
The State of North Carolina has established surface water quality standards under Title 15A of
the North Carolina Administrative Code 2B.0200 and is considered in compliance with the
CW A. For contaminants of concern at FCXS that have no North Carolina surface water
standard, the CW A standards will apply.
Table 2-5 provides the federal surface water criteria applicable to freshwater (North Carolina
designation Class C waters) for chemicals found to be chemicals of concern for any site medium.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Chemicals
Acetone
Benzene
Bromodichloromethane
Chloroform
I, 1-Dichloroethane
I, 1-Dichloroethene
cis-1,2-Dichloroethene
trans-1,2-Dichloroethene
1,2-Dichloroethene (total)
1,2-Dichloropropane
Tetrachloroethene
I, I, I -Trichloroethane
Trichloroethene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(b or k)fluoranthene
Benzo(a)pyrene
Bis(2-ethylhexyl)phthalate
NOA/G:\HOME\ WP\04400\011 \FSBAM-2.WP
Table 2-4
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: l
Date: June 1994
Federal Surface Water Quality Standards
for FCXS Contaminants of Concern
Aquatic Life-
Freshwater
/L
2-31
Human Health-
71
22
470
3.2
8.85
110,000
0.031
0.031
0.031
5.9
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Chemicals
Chrysene
Dibenzo(a,h)anthracene
Di-n-butylphthalate
Di-n-octylphthalate
Fluoranthene
Fluorene
Indeno(l ,2,3-cd)pyrene
Pentachlorophenol
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
Alpha-BHC
Beta-BHC
Gamma-BHC
Alpha-Chlordane
Gamma-Chlordane
DDD
DDE
DDT
Dieldrin
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Table 2-4 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Federal Surface Water Quality Standards
for FCXS Contaminants of Concern
Aquatic Life-
Freshwater
(µg/L)
13
0.08
0.0043 (chlordane)
0.0043 (chlordane)
0.001
0.00019
2-32
Human Health-
Fish Consumption
(µg/L)
0.031
0.031
12,000
370
14,000
0.031
8.2
11,000
0.013
0.046
0.063
0.00059
0.00059
0.00084
0.00059
0.00059
0.00014
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Chemicals
Endrin
Heptachlor
Heptachlor Epoxide
Aroclor 1254
2,3,7,8-TCDD (Dioxin)
Arsenic
Barium
Beryllium
Chromium
Copper
Manganese
Mercury
Nickel
Selenium
Strontium
Vanadium
Zinc
Table 2-4 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Federal Surface Water Quality Standards
for FCXS Contaminants of Concern
Aquatic Life-
Freshwater
(µg/L)
0.0023
0.0038
0.0038
0.014
190
210(111)', 11 (IV)
12'
0.012
160'
5
I JO•
Human Health-
Fish Consumption
(µg/L)
0.81
0.00021
0.0001 I
0.000044
0. 0000000 I 4
0.14
0.15
4,600
Note: Blank indicates that no standard has been promulgated.
a Based on an assumed water hardness of 100 rng/L.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA ft shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
2.3.2.2 Action-Specific Requirements
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
CW A regulations establish effluent standards for point source discharges as follows:
• Direct discharge to a surface water is governed by the NPDES pennitting
requirements (Section 402 of the CW A). Specific permitting requirements are
contained under 40 CFR 125, while specific effluent guidelines and standards are
given in 40 CFR 401. It should be noted that no categorical effluent guidelines
or standards have been established for hazardous waste sites.
• Indirect discharge to a POTW is governed by pretreatment regulations (Section
307(b) of the CWA). National pretreatment standards are addressed under 40
CFR 403. The standards specifically prohibit discharge of the following to a
POTW (40 CFR 403.5):
Ignitable or explosive wastewater
Reactive or toxic fume-generating wastewaters
Used oil
Solvent waste
Pollutants that pass through the POTW without treatment, interfere with
POTW operations, contaminate POTW sludge, or endanger the health or
safety of POTW workers
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Technology-Based Guidelines and Standards
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The standards of control for direct discharges are derived from Title III of the CW A. Section
301 (b) of the CW A requires all direct dischargers to meet technology-based requirements.
These requirements include, for conventional pollutants, application of the best conventional
pollutant control technology (BCT), and for toxic and nonconventional pollutants, the best
available technology economically available (BAT). EPA has determined the technology-based
requirements through effluent limitations guidelines for specific categories of industries, which
are translated into specific discharge limits by permit writers. Where effluent guidelines for
specific categories of industry or industrial category do not exist, e.g., CERCLA sites,
BCT/BAT technology-based treatment requirements are detem1ined on a case-by-case basis using
best professional judgement (BPJ). Once BPJ determination is made, the numerical effluent
discharge limits are derived by applying the levels of performance of a treatment technology to
the wastewater discharge.
2.3.3 Safe Drinking Water Act
The Safe Drinking Water Act (SDWA, 42 USC 300f et seq.) mandated EPA to establish
regulations to protect public health from contaminants in drinking water. As such, it can be
applied as an ARAR source for the development of soil cleanup goals for the protection of
groundwater. SDW A chemical-specific and action-specific ARARs have been identified and are
discussed in this section. No location-specific requirements were identified.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
2.3.3.1 Chemical-Specific Requirements
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The SDW A mandated that EPA establish regulations and standards to protect human health from
contaminants in drinking water. EPA has promulgated primary and secondary drinking water
-regulations and standards applicable to public water systems. National Primary Drinking Water
Standards (NPDWS) are established in 40 CFR 141 and are expressed as MCLs that are not to
be exceeded in public water supplies. The MCLs are enforceable human-health based standards
for public water supplies that consider available treatment technologies and cost of treatment.
National Secondary Drinking Water Standards (NSDWS) are established in 40 CFR 143 and are
expressed as Secondary Maximum Contaminant Levels (SMCLs) that should not be exceeded
in public water supplies. The SMCLs are nonenforceable (unless adopted as enforceable
standards on the state level), aesthetic-based guidelines that consider available treatment
technologies and cost of treatment.
In addition to the primary and secondary standards, EPA has established (40 CFR 141)
Maximum Contaminant Level Goals (MCLGs). The MCLGs are non-enforceable guidelines
based strictly on human-health considerations without regard for available treatment technologies
and/or the cost of treatment. For a particular parameter, MCLGs are established by EPA at the
time an MCL is established.
Table 2-6 summarizes the current and proposed SDW A MCLs, MCLGs, and SMCLs for the
contaminants of concern at the site. Contaminants of concern in groundwater are in bold print.
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This document was prepared by Roy F, Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-5
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Current and Proposed Federal Safe Drinking Water Act Standards
for FCXS Contaminants of Concern
Acetone No MCI,s
Benzene 5 0 Final
Bromodichloromethane 100' 0 Listed for further regulation
Chloroform 100' 0 Listed for further regulation
Chloromethane Listed for further regulation
1, 1-Dichlorocthanc Listed for further regulation
1,1-Dichloroethene 7 7 Final
cis-1,2-Dichloroethene 70 70 Final
trans-1,2-Dichloroethene 100 100 Final
1,2-Dichloroethene (total) Not separately regulated
1,2-Dichloropropanc 5 0 Final
Tetrachloroelhene 5 0 Final
1, 1, 1-Trichloroethane 200 200 Final
Trichloroethene 5 0 Fil'lal
Acenaphthene No MCl...s
Acenaphthylcne No MCl...s
Anthracenc No MCl...s
Benzo( a)anthracene 0.1 0 Proposed
Benzo(k )fluoranthene 0.2 0 Proposed
Benzo(a)pyrene 0.2 0 Final
His(2-ethylhexyl)phthalate 6 0 Final
Chrysene 0.2 0 Proposed
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This document was prepared by Roy F, Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Table 2-5 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Current and Proposed Federal Safe Drinking Water Act Standards
for FCXS Contaminants of Concern
CHEMICAL MCL MCLG SMCL Regulatory Status
Dibenzo( a,h )anthracene 0.3 0 -Proposed
I) i-n-b u tyl ph t ha late .. --No MCLs
pi-n-octylphthalate -.. .. No MCI-">
Fluoranthcne .. -.. No MCl.s
Fluorene .. --No MCLs
lndcno( 1,2,3-c,d)pyrenc 0.4 0 .. Proposed
Pentachlorophenol I 0 .. Final
Phenanthrcnc .. .. .. No MCL.s
Pyrene ---No MCLs
1,2,4-Trichlorobenzcnc 70 70 .. Proposed
Alpha-BHC --.. No MCLs
Beta-BHC -.. .. No MCL,;;
Gamma-HHC (Lindane) 0.2 0.2 -Final
Alpha-Chlordane 2 0 .. Final {for chlordane)
Gamma-Chlordane 2 0 .. Final (for chlordane)
DDD ---No MCLs
DDE .. .. .. No MCLs
DDT .. .. -No MCLs
Dieldrin .. .. -No MCLs
Endrin 2 2 .. Final
1-leptachlor 0.4 0 .. Final
Heptachlor Epoxide 0.2 0 -Final
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-5 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Current and Proposed Federal Safe Drinking Water Act Standards
for FCXS Contaminants of Concern
CHEMICAL MCL
Aroclor 1254 0.5
Ar..enic 50
Barium 2,000
Beryllium 4
Chromium (Total) 100
Copper Treatment
Manganese
Mercury 2
Nickel 100
Selenium 50
Strontium
Vanadium
Zinc
MCLG SMCL.
0
2,000
4
100
1.3 1,000
50
2
100
50
5,000
Regulatory Status
Under review
Final
Final
Final
Final. MCL treatment-dependent
Listed for further regulation.
SMCL final.
Final
Final
Final
Listed for further regulation
Listed for further regulation
MCL listed for further regulation.
SMCL final.
Notes: Only chemicals in bold are contaminants of concern in groundwater based on the Risk Assessment (WESI'ON, 1993).
• Total trihalomethanes.
Concentrations in µg/L.
-indicates that no standard has been promulgated.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
2.3.4 Clean Air Act
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision; 1
Date: June 1994
The Clean Air Act (CAA, 42 USC 7401 et seq.) mandated that EPA establish regulations to
protect ambient air quality. It can be applied as an ARAR to the site for remedial actions that
-potentially result in air emissions.
The following regulations have been established by CAA:
•
•
National Ambient Air Quality Standards (NAAQS)
Maximum emission standards as expressed under the National Emission Standards
for Hazardous Air Pollutants (NESHAP)
2.3.4.1 National Ambient Air Quality Standards (NAAQS)
NAAQS ( 40 CFR 50) have been developed by EPA for seven classes of pollutants: particulate,
sulfur oxides, nitrogen oxides, hydrocarbons, oxidants (ozone), carbon monoxide, and lead. The
NAAQS focuses on two levels of control: primary and secondary. The primary standards apply
exclusively to the protection of human health, while the secondary standards apply to the
prevention of property damage. It should be noted that these standards are not emission (i.e.,
discharge) standards.
Further, these are standards to be met for the ambient air after allowing for mixing of the
particular discharge with the ambient air. State implementation plans are developed by I individual states and contain the actual abatement requirements necessary to achieve compliance
with the NAAQS.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. ft shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
NAAQS attainment requirements are applicable only to major sources which are defined as
emitting over 100 to 250 tons per year of regulated pollutants. NAAQS standards are not
applicable to the site because emissions of this magnitude will not be generated during the
remedial actions.
2.3.4.2 National Emission Standards for Hazardous Air Pollutants (NESHAP) Standards
NESHAP Regulations (40 CFR 61) currently cover seven separate contaminants, including
benzene. Subpart FF of 40 CFR 61 provides the national emission standard for benzene waste
operations. Application of this subpart is limited, however, to owners and operators of chemical
manufacturing plants, coke byproduct recovery plants, and petroleum refineries; therefore, these
regulations do not specifically apply as potential ARARs to this site.
2.3.5 Occupational Safety and Health Act
The Occupational Safety and Health Act (OSHA) (29 USCA 651) resulted in creation of the
Occupational Safety and Health Agency to protect worker safety and to administer regulatory
control for worker safety.
Under OSHA, general industry standards have been promulgated under 29 CFR 1910. The
action-specific requirements given under 29 CFR 1910.120, Hazardous Waste Operations and
Emergency Response, specifically apply to the site. Those requirements include provisions for:
• A written safety and health program (29 CFR 1910.120 (b)).
• Characterization and analysis of the hazardous waste site (29 CFR 1910.120 (c)) .
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
•
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•
•
•
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: '1
Date; June 1994
Appropriate site control procedures (29 CFR 1910.120 (d)) .
Training (29 CFR 1910.120 (e)) .
Institution of medical surveillance program (29 CFR 1910.120 (f)) .
Implementation of engineering controls, work practices, and personal protection
equipment (29 CFR 1910.120 (g)).
Monitoring of hazardous substance exposures (29 CFR 1910.120 (h)) .
Information program (29 CFR 1910.120 (i)) .
Handling, transportation, labeling, and disposal of hazardous substances and
contaminated soils, liquids, and other residues. (29 CFR 1910.120 (j)).
• Decontamination (29 CFR 1910.120 (k)).
•
•
•
•
•
•
Implementation of an emergency response plan (29 CFR 1910.120 (I)) .
Illumination (29 CFR 1910.120 (m)) .
Provision of sanitary facilities (29 CFR 1910.120(n)) .
Introduction of improved protection procedures (29 CFR 1910.120 (o)) .
Operations conducted at TSD facilities (29 CFR 1910.120 (p)) .
Emergency response to hazardous substance releases. (29 CFR 1910. 120 (q)) .
2.3.6 Hazardous Materials Transportation Act
Through the Hazardous Materials Transportation Act ( 49 USC 1801-1813), regulations regarding
the transportation of hazardous materials were promulgated by the Department of Transportation
(DOT) under 49 CFR Parts 107 and 171-I 77. Transportation of DOT-defined hazardous
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
materials off-site is a potential remedial action for the site. The following action-specific
regulatory requirements represent potential ARARs:
•
•
•
•
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Hazardous materials table (49 CPR 172.101) listing DOT-designated hazardous
materials and waste, along with a summary of basic shipping requirements.
Required manifest information (49 CPR 172.101, 172.203, and 173) including
proper shipping name, hazard classification, and identification number.
Transportation mode requirements (49 CPR 172.101 and 174-177) .
Packaging. labeling. and marking requirements (49 CPR 172. 178, and 179) .
Transportation placarding requirements (49 CPR 172, Subpart P) .
I 2.3. 7 Protection of Wetlands
I Through Executive Order No. 11990, regulations regarding protection of wetlands were
promulgated by EPA under 40 CPR 6.302(a). The following location-specific regulatory I requirements represent potential ARARs:
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Avoid, to the extent possible, adverse impacts associated with the destrnction or
loss of wetlands.
Avoid new constrnction on wetlands unless no other practical alternative exists .
Prepare a wetlands assessment if wetlands will be affected.
Avoid adverse effects or minimize them if no practicable alternative to the action
exists.
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This document was prepared by Roy F. Weston, Inc,, expressly for EPA.. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
No wetlands have been identified during the Rls conducted at the site; therefore, this regulation
may not be applicable.
2.3.8 Floodplain Management
Through Executive Order No. 11988, regulations regarding protection of W(ltlands were
promulgated by EPA under 40 CFR 6.302(b). The following location-specific regulatory
requirements represent potential ARARs:
• Avoid, to the extent possible, adverse
indirect development of a floodplain.
impacts associated with the direct or
•
•
Prepare a floodplains assessment if an action will be located in or will affect a
floodplain.
Avoid adverse effects or minimize them if no practicable alternative to the action
exists.
Since the site is not located in a floodplain, this regulation is not applicable.
2.3.9 Regulations Protecting of Landmarks, Historical, and Archeological Sites
The regulations associated with protection of landmarks, historical, and archeological sites are
specified under 40 CFR 6.301. The following location/action-specific regulatory requirements
represent potential ARARs:
• National Natural Landmarks -Under the Historic Sites Act of 1935, 16 USC 461
et seq., the Secretary of Interior is authorized to designate areas as national
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
•
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
natural landmarks for listing on the National Registry of Natural Landmarks. In
conducting an environmental review of a proposed action, the existence and
location of natural landma"rks shall be considered to avoid undesirable impacts
upon such landmarks.
Historic. Architectural. Archeological. and Cultural sites -Under Section 106 of
the National Historic Preservation Act of 1966. as amended, 16 USC 470 et seq.,
and Executive Order 11593, if an action affects any property with historic,
archeological, or cultural value that is listed on or eligible for listing on the
National Register of Historic Places, the responsible official shall comply with the
procedures for consultation and comment promulgated by the Advisory Council
on Historic Preservation in 36 CPR 800.
Historic, Prehistoric. and Archeological Data -Under the Archeological
Preservation Act of 1974, 16 USC 469 et seq, and Executive Order 11593, if an
action may cause irreparable loss or destruction of significant scientific,
prehistoric, historic, or archeological data, data recovery and preservation
activities shall be conducted in accordance with implementing procedures
promulgated by the Secretary of Interior.
No historic sites listed in the National Register in the Statesville area were identified in the RI.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
2.3.10 Endangered Species Act
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date; June 1994
The Endangered Species Act (16 USC 1531 et seq.) of 1973 is applicable if endangered species
or threatened species are present in the area. This Act requires that action be performed to I -conserve endangered or threatened species. Any proposed activities must not destroy or
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adversely modify the critical habitat upon which the species depend.
No endangered or threatened species have been identified for Iredell County; however, three
candidate species have been identified (phone conversation with U.S. Fish and Wildlife
Commission, January 1993):
•
•
•
Bog turtle
Tall larkspur
Heller's trefoil
If any of these species are added to the endangered or threatened species list, then the I Endangered Species Act would be applicable.
I 2.3.11 Fish and Wildlife Coordination Act
I The purpose of the Fish and Wildlife Coordination Act (16 USC 666 et seq.) is to conserve and
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promote conservation of fish and their habitats. The Act pertains to activities that modify a
stream or river and affect fish or wildlife. Actions must be taken to protect the fish and wildlife
resources affected by site activities. Fish and Wildlife Coordination Act is potentially applicable
to the site if remedial action involves discharge of effluent to an unnamed tributary of Third
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This document was prepared by Roy F, Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
Creek, which eventually discharges to the South Yadkin River located approximately 15 miles
east of the site.
2.3.12 EPA OSWER Soil Screening Levels
The Draft EPA Soil Screening Levels, published by the Office of Solid Waste and Emergency I Response (OSWER) in June 1993, attempt to standardize the remedial planning and remedy
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selection process thereby reducing the time it takes to start cleanups. The SSLs are not cleanup
standards; their intent is to screen out from further consideration those soils not believed to be
of any potential risk to health and human life. Concentrations of the contaminants in soil above
the "action levels" listed in Table 2-7 would generally require further site investigation,
regardless of the site specifics.
2.4 STATE ARARs
2.4.1 North Carolina Hazardous Waste Management Rules and Solid Waste
Management Law
The North Carolina Solid and Hazardous Waste Management Act (General Status of NC,
Chapter 130A, Article 9) represents the state level equivalent of the Federal RCRA. Through
this act, the Division of Solid Waste Management Laws established rules and regulations for:
•
•
•
Management of solid waste
Management of hazardous waste
Siting of hazardous waste treatment and dispo'sal facilities
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. Jt Shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-6
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
EPA Soil Screening Levels for Residential Land Use
for FCXS Contaminants of Concern
-Risk-based Goal Risk-based Goal
(mg/kg) (mg/kg)
Chemical (Ingestion only) (Inhalation only)
Alpha-BHC 0.10 C 0.05 C
Beta-BHC
Gamma-BHC (Lindane)
Endrin
Chlordane 0.49 C 1.90 C
Pentachlorophenol (I) c --
DDT 1.90 C 69 C
DDD
Trichloroethene 58 C 16 C
Tetrachloroethene 12 C 46.00 C
2,3,7,8-TCDD (dioxin)
NOTE: Screening Levels based on human health criteria only.
Blank indicates that no screening level has been promulgated.
c -Calculated values correspond to a cancer risk level of I in 1,000,000.
Groundwater Groundwater Groundwater
Migration Migration Migration
-Unadjusted--with 10 DAF--with 100 DAF-
(mg/kg) (mg/kg) (mg/kg)
0.0001 * 0.001 * 0.010
0.200 2 20
0.820 8.2 82
0.230 2.3 23
0.001 * 0.010 * 0.1
0.003 * 0.030 0.3
(!) -A preliminary remediation goal of I ppm has been set for PCB-1260 based on consideration of tl1e nine criteria of tl1e NCP.
* -Level at or below Contract Laboratory Program required quantification limit for Regular Analytical Services (RAS), since
detection at screening level may not be possible.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The regulations may apply to the treatment and disposal of dioxin-contaminated soils.
2.4.2 North Carolina Water and Air Resources Act
-The Ncirth Carolina (NC) Water and Air Resources Act (General Statutes of NC, Chapter 143,
Articles 21, 21B) represents the state equivalent of the Federal CWA and CAA. The purpose
of this act is to achieve and to maintain a total environment of superior quality. Standards of
water and air purity are designed to protect human health, to prevent injury to plant and animal
life, to prevent damage to public and private property, to insure the continued employment of
the natural attractions of the State, to encourage the expansion of employment opportunities, and
to provide a permanent foundation for healthy industrial development. The NC Water and Air
Resources Act is potentially applicable to the site as an action-specific ARAR.
2.4.3 North Carolina Drinking Water Act
The North Carolina Drinking Water Act (General Statutes of NC, Chapter 130 A, Article JO)
represents the state-level equivalent of the Federal SDW A. Through this act, the NCDEHNR
Water Quality Section has established standards to regulate water systems within the State which
supply drinking water that may affect the public health.
2.4.4 North Carolina Water Pollution Control Regulations
The North Carolina Water Pollution Control Regulations are specified in NCAC, Title 15,
Chapter 2. Subchapter 2H discusses the procedures for permits and approvals. Section 2H.0JO0
discusses the regulations regarding wastewater discharges to surface waters. These rules may
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole .or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision; 1
Date: June 1994
apply to FCXS due to discharge of effluent to surface waters or to a pretreatment facility. The
information about the forms to be completed and supporting documents to be submitted for I permit application is given in these rules. The time requir~d for processing an application and
issuing a permit is about 90 to 120 days.
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2.4.5 North Carolina Drinking Water and Groundwater Standards
The State of North Carolina has promulgated groundwater classifications and water quality
standards under Title 15, Subchapter 2L, Sections .0200 and .0201, respectively.
Groundwater in North Carolina is classified based on the groundwater usage, the conditions
related to best usage, and the occurrence of groundwater as follows:
• Class GA Waters:
Best Usage -Existing or potential source of drinking water supply for
humans.
Conditions Related to Best Usage -This class is intended for those
groundwaters in which chloride concentrations are equal to or less than
250 mg/L, and are considered suitable for drinking in their natural state,
but may require treatment to improve quality related to natural conditions.
Occurrence -In the saturated zone.
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This document was prepared by Roy F, Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
• Class GSA Waters:
•
Best Usage -Existing or potential source of water supply for potable
mineral water and conversion to fresh waters.
Conditions Related to Best Usage -This class is intended for those
groundwaters in which the chloride concentrations due to natural
conditions are in excess of 250 mg/L, but which otherwise may be
considered suitable for use as potable water after treatment to reduce
concentrations of naturally occurring substances.
Occurrence -In the saturated zone.
Class GC Waters
Best Usage -Source of water supply for purposes other than drinking.
Conditions Related to Best Usage. -This class includes those
groundwaters that do not meet the quality criteria of waters having a
higher classification and for which efforts to restore in-situ to a higher
classification would not be technologically feasible or in the best interest
of the public.
Occurrence -In the saturated zone, as determined by the commission on
a case by case basis.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
The groundwater quality standards for the most stringent Class (GA), which appear to apply to
the FCXS site, are presented in Table 2-8.
2.4.6 North Carolina Surface Water Quality Standards
The surface water classifications and surface water quality standards have been promulgated by
the State of North Carolina under the Title 15A NCAC 2B .0100 and 15A NCAC 2B.0200,
respectively.
2.4.6.1 Surface Water Classification
The following surface water classifications have been promulgated by the State of North
Carolina:
(A) Freshwater Classification
•
•
Class C: Freshwaters protected for secondary recreation, fishing, and aquatic life
including propagation and survival; all freshwaters are classified to protect these
uses at a minimum.
Class B: Freshwaters protected for primary recreation which includes swimming
on a frequent and/or organized basis and all Class C uses.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-7
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Class GA Groundwater Quality Standards
for FCXS Contaminants of Concern
CHEMICAL
Acetone
Benzene
Bromodichloromethane
Chloroform
Chloromethane
I, 1-Dichloroethane
I, 1-Dichloroethene
cis-1,2-Dichloroethene
trans-1,2-Dichloroethene
1,2-Dichloroethene (total)
1,2-Dichloropropane
Tctrachloroethene
I, I, 1-Trichloroethane
Trichloroethene
Acenaphthene
Accnaphthylene
Anthracene
Benzo(a)anthracene
Benzo(k)fluoranthene
Benzo(a)pyrene
NOR/G:IHOME\\I\IP\04400\011\FSBRM-2.'vYP
CLASS GA GROUNDWATER QUALITY STANDARD
{µg/L)
700
0.19
700
7
70
70
0.56
0.7
200
2.8
2-53
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, i_n whole ·or in part,
without the express written permission of EPA.
Table 2-7 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Class GA Groundwater Quality Standards
for FCXS Contaminants of Concern
CHEMICAL
Bis(2-ethylhexyl)phthalate
Cluysene
Dibenzo(a,h)anthracene
Di-n-butylphthalate
Di-n-octylphthalate
Fluoranthene
Fluorene
lndeno( 1,2,3-c,d)pyrene
Pentachlorophenol
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
Alpha-BHC
Beta-BHC
Gamma-BHC (Lindane)
Alpha-Chlordane
Gamma-Chlordane
DDD
DDE
DDT
Dieldrin
NORIG:\HOM E\""'1?\04400\01 1 \FSBRM-2. WP
CLASS GA GROUNDWATER QUALITY STANDARD
(µg/L)
3
700
0.3
0.2
0.027
0.027
2-54
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-7 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Class GA Groundwater Quality Standards
for FCXS Contaminants of Concern
CHEMICAL
Dioxin
Endrin
Heptachlor
Heptachlor Epoxide
Aroclor 1254
Arsenic
Barium
Beryllium
Chromium
Copper
Manganese
Mercury
Nickel
Selenium
Strontium
Vanadium
Zinc
CLASS GA GROUNDWATER QUALITY STANDARD
(µg/L)
2.2 X l0'7
2
0.008
0.004
50
2,000
50
1,000
50
I.I
100
50
2,100
Notes: Blank indicates that no standard has been promulgated.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
(B)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
• Class WS-1: Waters protected as water supplies which are in essentially natural
and undeveloped (not urbanized) watersheds; no point source discharges of
wastewater are pennitted, except those specified in Rule .0104 of Subchapter 2B
of Part 15A of the North Carolina Administrative Code (NCAC).
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Class WS-11: Water protected as water supplies which are generally in
predominantly undeveloped watersheds.
Class WS-III: Water protected as water supplies which are generally in low to
moderately developed watersheds.
Class WS-IV: Water protected as water supplies which are generally in
moderately to highly developed watersheds or protected areas.
Class WS-V: Water protected as water supplies which are generally upstream
and draining to Class WS-IV waters or waters previously used for drinking water
supply. The water, following treatment, will meet the maximum contaminant
levels considered safe for drinking, culinary, or food .processing purposes.
Tidal Salt Water Classification
• Class SC: Saltwaters protected for secondary recreation, fishing, and aquatic life
including propagation and survival; all saltwaters are classified to protect these
uses at a minimum.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
(C)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision; 1
Date: June 1994
• Class SB: Saltwaters protected for primary recreation which includes swimming
on a frequent and/or organized basis and all Class SC uses.
• Class SA: Suitable for commercial shell fishing and all other tidal saltwater uses.
Supplemental Classification
• Troutwaters (Tr): Suitable for natural trout propagation and maintenance of
stocked trout.
• Swamp Waters (Sw): Waters which have low velocities and other natural
characteristics which are different from adjacent streams.
•
•
Nutrient Sensitive Waters (NSW): Waters which require limitations on nutrient
inputs.
High Quality Waters (HQW): Waters which are rated as excellent based on
biological and physical/chemical characteristics through division monitoring or
special studies; native and special native trout waters (and their tributaries)
designated by the Wildlife Resource Commission; primary nursery areas (PNA)
designated by the Marine Fisheries Commission or other appropriate agencies;
critical habitat areas recognized by the Wildlife Resource Commission or the
Department of Agriculture; and all water supply watersheds which are either
classified as WS-I or WS-II or those of which a formal petition for reclassification
NOA/G:\HOME\ WP\04400\011 \FSBAM-2.WP 2-57
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
as WS-I or WS-II has been received from the appropriate local government and
accepted by the Division of Environmental Management and all Class SA waters.
• Outstanding Resource Waters (ORW): Unique and special waters of exceptional
state or national recreational or ecological significance which require special
protection to maintain existing uses.
Under North Carolina surface water regulations, Third Creek is a Class C freshwater.
2.4.6.2 Standards for Toxic Substances and Temperature
According to these standards, the concentrations of toxic substances in surface waters, either
alone or in combination with other wastes, must not render waters injurious to aquatic life or
wildlife, recreational activities, public health, or impair the waters for any designated uses.
(a) Aquatic Life Standards: The concentration of toxic substances will not result in
chronic toxicity.
(b) Human Health Standards: The concentrations of toxic substances must not exceed
the level necessary to protect human health through exposure routes of fish ( or
shellfish) tissue consumption, water consumption, or other route identified as
appropriate for the water body. For non-carcinogens, these concentrations will
be determined using a reference dose (RID) as developed by the EPA.
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This document was prepared by Roy F. Weston, Inc,, expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
2.4.6.3 Water Quality Standards Applicable to Surface Waters of North Carolina
The Environmental Management Commission has established an Antidegradation Policy to
maintain, protect, and enhance water quality within the State of North Carolina. Pursuant to this
-policy, 'the requirements of 40 CFR 131 .12 are adopted by reference in accordance with General
Statute 150B-14(b). These requirements are based on the type of usage of the surface water:
(A)
(B)
(C)
Existing uses and water quality to protect such uses by properly
classifying surface waters and having standards sufficient to protect these
uses.
Present and anticipated usage of waters with quality higher than the
standards, including any uses not specified by the assigned classification
(such as outstanding national resource waters or waters with exceptional
quality) and that will not allow degradation of the quality of waters with
quality higher than the standards necessary to maintain existing and
anticipated usage of those waters. The procedure to be followed to meet
these requirements is presented in 15A NCAC 2B.0201 (c).
Present and anticipated usage of High Quality Waters (HQW), including
any uses not specified by the assigned classification (such as outstanding
national resource waters or waters with exceptional quality) and will not
allow degradation of the quality of HQW below the quality necessary to
maintain existing and anticipated usage of those waters. The procedure
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
to be followed to meet these requirements is presented in 15A NCAC 2B
.020l(d).
2.4.6.4 Surface Water Quality Standards Applicable to FCXS
Surface water quality standards which are potentially applicable to possible effluent from the
FCXS site are presented in Table 2-9.
2.4. 7 North Carolina Air Pollution Control Regulations
The North Carolina Air Pollution Control Laws are given in general statutes of North Carolina,
Chapter 143. The air pollution control regulations are given in 15A NCAC. These regulations
apply primarily to the air stripping system proposed for OU! (groundwater) at FCXS.
NOA/G:\HOME\ WP\04400\011 \FSBAM•2.WP 2-60
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This document was prepared by Roy F. Weston, Inc., expressly ror EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-8
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Surface Water Quality Standards
for FCXS Contaminants of Concern
Chemical
Acetone
Benzene
Bromodichloromethane
Chloroform
Chloromethane
I, 1-Dichloroethane
I, 1-Dichloroethene
cis-1,2-Dichloroethene
trans-I , 2-Dichloroethene
1,2-Dichloroethene (total)
1,2-Dichloro ro ane
Tetrachloroethene
I, I, I-Trichloroethane
Acena hthene
Acena hthylene
Anthracene
Benzo(a)anthracene
Benzo(b or k)fluoranthene
Benzo(a) rene
Bis(2-ethylhexyl)phthalate
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Aquatic Life-
Class C Freshwater"
(µg/L)
2-61
Human Health-
Fish Consumptionb
(µg/L)
71.4
0.0311 (cPAHs)
0.0311 (cPAHs)
0.0311 (cPAHs)
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 2-8 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Surface Water Quality Standards
for FCXS Contaminants of Concern
Chemical
Chrysene
Dibenzo(a,h)anthracene
Di-n-but I hthalate
Di-11-octyl hthalate
Fluoranthene
Fluorene
lndeno(l,2,3-c,d) rene
Pentachloro henol
Phenanthrene
Pyrene
Al ha-BHC
Beta-BHC
Gamma-BHC (Lindane)
Al ha-Chlordane
Gamma-Chlordane
DDD
DDE
DDT
Dieldrin
Endrin
Heptachlor
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Aquatic Life-
Class C Freshwater"
(µg/L)
0.01
0.004 (chlordane)
0.004 (chlordane)
0.001
0.002
0.002
0.004
2-62
Human Health-
Fish Consumption"
(µg/L)
0.0311 (cPAHs)
0.0311 (cPAHs)
0.0311 (cPAHs)
0.000588
0.000588
0.000591
0.000144
0.000214
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Chemical
Aroclor 1254
Arsenic
Barium
Be Ilium
Chromium
Co er
Manganese
Mercury
Nickel
Selenium
Strontium
Vanadium
Zinc
Notes:
Table 2-8 (Continued)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 2
Revision: 1
Date: June 1994
North Carolina Surface Water Quality Standards
for FCXS Contaminants of Concern
Aquatic Life-
Class C Freshwater'
(µg/L)
0.001 (PCBs)
50
6.5
50
7 (AL)
0.012
88
5
50 (AL)
Human Health-
Fish Consumption'
(µg/L)
0.000079 (PCBs)
1.4 X 1Q·'
0.117
• Fresh Surface Water Classifications and Standards, North Carolina Administrative Code .0211.
'Standards for Toxic Substances and Temperature, North Carolina Administrative Code .0208. Additional criteria
for the protection of aquatic life and human health are to be determined by risk assessment.
AL = Action Level not to be exceeded in a receiving water by a discharge under low flow criterion.
cPAHs = Carcinogenic polynuclear aromatic hydrocarbons.
Blank indicates that no standard has been promulgated.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
SECTION 3
REMEDIAL OBJECTIVES
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 3
Revision: 1
Date: June 1994
The purpose of this FS is to evaluate methods to address contamination of the site soils
(Operable Unit 2) at the FCXS site in order to protect human health and the environment. A I -separaie FS to address the characterized groundwater, surface water, and sediment (Operable
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Unit I) was prepared and submitted to EPA in May 1993.
The primary remedial action objectives for soils at the FCXS site are:
• To achieve remediation (cleanup) levels for the contaminants of concern.
• To mitigate the potential risks to human health posed by contact with
contaminated soil.
3.1 REGULATORY REQUIREMENTS
In soil remediation, there are generally two types of regulatory performance requirements that
have to be met:
(I) Remediation Levels -Remediation levels are target concentrations for soil which
will remain on-site after completion of remedial action. They are typically based
on Federal or state ARARs, and/or the results of a baseline risk assessment(s).
Remediation typically continues until these levels are met.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
(2)
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 3
Revision: 1
Date: June 1994
Treatment/Disposal Standards -Treatment or disposal standards apply when soils
are removed and treated or disposed and RCRA or TSCA regulations are relevant
or applicable. This may include Destruction Removal Efficiency (DRE)
Standards for incineration or disposal restrictions for landfilling.
Therefore, two sets of performance requirements for contaminants of concern may need to be
satisfied before remediation can be considered complete.
3.2 SOIL REMEDIATION GOALS
No Federal or North Carolina ARARs have been established for soil remediation. Therefore,
soil remediation goals were developed specific io the FCXS site. Based on discussions with
EPA, the following conclusions were reached.
•
•
•
•
A remediation level of I mg/kg total pesticides was selected. This level was
provided to the EPA by the State of North Carolina Superfund Section as an
estimated background level at similar sites.
Metals and BNA will not be included in the development of remediation levels,
since the levels of these chemicals detected are comparable to background levels
or non-site related contamination.
For dioxins, EPA-Region IV has established the remediation level of lµg/kg
based on a TEQ value of I ppb. The EPA believes that this action level typically
represents a risk level in the range of 104 to 10·6 and considers this to be an
acceptable range of risk. It should be noted that no soil areas at the FCXS site
exceed this remediation goal.
The remediation level for pentachlorophenol will be 3.2 mg/kg, which represents
the 10·6 risk level for the site. A discussion on the risk assessment methodology
is provided in Subsection 3.2.1.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 3
Revision: 1
Date: June 1994
3.2.1 Risk Assessment Results
The risk assessment for the FCXS site was conducted to evaluate the potential risk associated
with contaminants present at the site. The results were presented in the Risk Assessment Report,
_ FCX-OU2 Statesville Superfund Site, June 1994.
The RA evaluated five different exposure scenarios for current and future uses:
•
•
•
•
•
Current off-site residents
Current on-site trespassers
Future on-site residents
Future worker with the building present
Future worker with the building demolished
Under these five scenarios, vanous exposure pathways were investigated, including dermal
contact with surface soils, ingestion of soils and groundwater, and inhalation of groundwater
volatiles while showering,
Risk levels for carcinogenic and noncarcinogenic risk were estimated for these scenarios. These
risk levels were then utilized to develop risk-based cleanup levels using the following approach:
I.
2.
The calculated risk results for all exposure scenarios evaluated were reviewed to identify
those contaminants of concern (COCs) whose concentrations contributed to a lifetime
excess cancer risk greater than I x JO·' or a noncarcinogenic hazard index (HI) greater
than I.
Remedial Goal Options (RGOs) were calculated for these COCs by determining the
concentrations at which the potential risk would equal I x JO·' or the HI would equal I.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 3
Revision: 1
Date: June 1994
RGOs for all COCs were higher than the EPA-proposed levels with the exception of the level
for pentachlorophenol (PCP). Therefore, the RGO for PCP was adopted as the remediation
level.
3.3 TREATMENTffiISPOSAL STANDARDS
If FCXS soil is treated and disposed on-site, the land disposal restrictions will apply requiring
the soil to meet treatment standards. Also, if the treated soils are disposed of elsewhere, they
will need to meet the land disposal restrictions. If the soil is determined to be non-hazardous,
land disposal restrictions will not apply.
3.4 SUMMARY OF SOIL REMEDIATION LEVELS AND TREATMENTffiISPOSAL
STANDARDS
Remediation levels for FCXS soil are summarized in Table 3-1. The applicability of the
treatment/disposal standards will depend on the TCLP test results and the ultimate disposal
option selected for the soil. Maximum PCE and TCE concentrations were below all potential
goals and standards, so they are not considered COCs for FCXS soil.
Figure 3-1 presents the estimated areal extent of contamination based upon the remediation
levels. The areas shown extend halfway to the nearest soil boring sample that exhibited no
contaminant levels or were below the remediation levels. The estimated volume of contaminated
soils using these remediation goals is 6,945 cubic yards which assumes an excavation depth
corresponding to the depth of contamination from soil boring samples collected at the site. I These depths were rounded to the nearest I', 3', 6', or 10' interval. After each area is
excavated, soil samples will be collected and analyzed to verify that the underlying soil did not
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 3
Revision: 1
Date: June 1994
contain contaminants of concern above the remediation levels. The estimated volumes will be
refined during the design phase, as necessary.
Table 3-1
Soil Remediation Levels
Contaminant Remediation Level
(mg/kg)
Total Pesticides• I
Chlordane --
Endrin --
Dieldrin --
DDD --
DDT --
BHC Compounds --
Dioxins * 0.001
Pentachlorophenol 3.2
,., Pesticides include chlordane, a-BHC, /1-BHC, endrin, dieldrin, DDT, DDD, DDE, aldrin, heptachlor.
• TEQ value.
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sj-
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WJ
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SOIL SAMPLE LOCA TlON
EXCEEDING CLEANUP LEVEL
ESTit,4AlED AREAL EXTI:NT OF
REQUIRED REMEDIATION.
TOTAL ARE:A: 51480 SQ. FT.
-
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RESIDENTIAL
AREA
--- -- -
BURLINGTON
INDUSTRIES
--- --·--
'x
)
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BASE UAP SOURCE: EPA SITE IAAP DH1E1J.43 !_, 0 150 300 ◊◊
SCALE FEET
G::t--------------------------,------_:_------=,-,=-~=:,-;;=---------_j
II
u l/1
r-= _,
Cl.
FCX-STATESVILLE
STATESVILLE. NORTH CAROLINA
APPROXIMATE EXCAVATION AREAS
BASED ON REMEDIATION LEVELS
FIGURE 3-1
DRA\JN
D.O.
CHECKED APPROVED ATE
'J, □. NO.
04400-11-21
D\JG. NO.
04400005
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
SECTION 4
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES
The objective of this section is to identify remedial technologies which may be appropriate for
soil remediation at FCXS. Technologies that do not adequately satisfy the criteria established
during the screening process will be eliminated from further consideration at this point. SARA
guidelines emphasize the use of treatment technologies that permanently and significantly reduce
the toxicity, mobility, or volume of waste. The technologies identified which satisfy the criteria
and appear to be acceptable as components of final remedial actions will be retained for further
evaluation and potential inclusion in remedial alternatives developed for the site.
Remedial technologies have been screened based primarily on effectiveness and
implementability. The effectiveness evaluation focuses on: (I) the potential effectiveness of
process options in handling the estimated areas or volumes of media and meeting the remediation
goals identified in the remedial action objectives; (2) the potential impacts to human health and
the environment during the constmction and implementation phase; and (3) how proven and
reliable the process is with respect to the contaminants and conditions at the site.
Implementability encompasses both the technical and administrative feasibility of implementing
a technology. Technical implementability is used as an initial screen of technology types and
process options to eliminate those that are clearly unworkable at the site. Administrative aspects
include the ability to obtain necessary permits; the availability of treatment, storage, and disposal
services; and the availability of necessary equipment and skilled workers to implement the
technology.
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This document was prepared by Roy F, Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section; 4
Revision: 1
Date; June 1994
Cost plays an infonnational role in the screening of process options. Relative capital and I operations & maintenance (O&M) costs are used rather than detailed estimates. At this stage
in the process, the cost analysis is made on the basis of engineering judgment, and each process I is evaluated as to whether costs are high, medium, or low relative to other process options in
the same technology type with comparable effectiveness.
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Based upon these criteria, a recommendation is then made to retain or eliminate the technology
for further consideration in the detailed analysis. A summary of the retained technologies is
presented in Section 4.2.
The soil remediation technologies that are evaluated in this section are divided into the following
categories:
• No Action
• Institutional Controls
•
•
•
•
•
•
•
Containment Technologies
Removal Technologies
Physical Treatment Technologies
Chemical Treatment Technologies
Thennal Treatment Technologies
Biological Treatment Technologies
Disposal Options
4.1 NO ACTION
Description -Under the no action alternative, no remedial measures would be implemented. All
contaminated soil beneath the existing structures and surrounding areas would be left in place.
Direct exposure to contamination under the buildings would not occur unless the site buildings
were removed and the subsurface soils were disturbed. If the buildings were removed, surface
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
water would also contact contaminated soil and possibly leach additional contamination to
groundwater.
Effectiveness -This option may be effective based on the existing buildings acting as a barrier
between most of the contaminated soil and means of exposure and migration, unless the
buildings are removed.
Implementability -The no action alternative can be easily implemented as it does not require any
present or future commitments.
Cost -The only costs associated with this alternative would be for performing five-year reviews.
Recommendation -This option will be held for further consideration as required under the NCP
and used as a basis for comparison with other alternatives.
4.2 INSTITUTIONAL CONTROLS
4.2.1 Deed Restrictions
Description -In this option, the property deed would be amended to include a stipulation
restricting the demolition of the existing structures by future owners. If contaminated soil is
disturbed, conditions of the deed would require the landowner to properly handle, treat, and/or
dispose of the soil in compliance with Federal, state, and local requirements. The site would
also be required to remain in industrial use, not residential use. Deed restrictions would also I place limitations on. the future use of on-site groundwater.
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This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Effectiveness -This option would be effective in protecting human health.
Costs -Capital costs associated with this operation would be minimal, consisting primarily of
legal fees to amend the deed. Costs to perform five-year reviews would also be included.
Recommendation -This option will be retained for further consideration.
4.3 CONTAINMENT TECHNOLOGIES
The process option being considered for soil containment is capping.
4.3.1 Capping
Description -Capping the area consists of covering an area with low-permeability materials.
As a result, the infiltration of precipitation and surface water is reduced and the leaching of soil
contaminants is limited. Most of the contaminated soils have been identified beneath existing
structures on the site and can be considered capped.
Additional capping would be required east of the buildings where some soil contamination was
detected. Capping in this area could be either clay or paving (such as concrete or asphalt).
Given the likely future industrial use of the site, the relatively small area to be capped, and the
paving already in place, paving will be considered as the preferred capping option.
Effectiveness -This alternative is effective for containing contaminated soil and preventing
downward migration of soil contaminants.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Implementability -Since much of the site is already capped, this technology 1s easily
implemented.
Cost -Costs associated with implementing this technology will be relatively low. Five-year
review costs would also be included.
Recommendation -This option is potentially applicable and will be retained for further
consideration.
4.4 REMOVAL TECHNOLOGIES
4.4.1 Excavation
Description -Excavation requires the physical removal of contaminated soils from the site and
disposing of them in an appropriate manner in compliance with Federal, state, and local
regulations. This process could be used in conjunction with an ex-situ remedial alternative
whereby the cleaned soil would be returned to the excavation (after delisting or similar EPA
authorization), or a soil removal alternative whereby the excavated soils would be evaluated for
waste characterization and disposed of at a properly permitted facility. The excavation would
be filled with clean fill material from an off-site source or by the treated soil once remediation
was complete.
Effectiveness -Excavation is effective at removmg site contamination, although by itself it
doesn't detoxify the waste and may simply transfer it to another location.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Implementability -Demolition and removal of the existing site building above the contaminated
areas would be required.
Cost -The excavation activity itself would be relatively inexpensive; however, treatment and/or
disposal of the soil and demolition and disposal of the buildings would increase costs
significantly.
Recommendation -This alternative will be retained for further evaluation.
4.5 PHYSICAL TREA'IMENT TECHNOLOGIES
The process options being considered m this category are soil washing, stabilization, soil
flushing, and in-situ volatilization.
4.5.1 Soil Washing
Description -Soil washing refers to methods for removing contaminants and/or fine soil particles
to which they are adsorbed by contacting soil particles with reagents that consist of a
water/surfactant or water/solvent solution. The waste chemicals are solubilized and retained in
the fluid phase. The scrubbing action can disintegrate soil aggregates, freeing contaminated
fines from the coarser sands and gravels. In addition, the abrasive scouring action removes
surficial contamination from larger particles. Soil washing is usually perfonned using a I multistaged batch process. Soil washing would require the excavation and staging of
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contaminated materials.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Effectiveness -Extensive bench-scale treatability testing would have to be perfonned to evaluate
the effectiveness of this technology on soil conditions at FCXS. Because the contaminated soil
is primarily fine-grained saprolite, removal of the fine-grained soil would essentially remove all
the soil, leaving little to backfill and a high volume for disposal. In addition, separation of
contaminants from the saprolite may prove difficult.
Implementability -Demolition of existing buildings would be required m order to access
contaminated soils.
Cost -Costs would be moderate to high due to the high percentage of fine-grained soil.
Recommendation -This treatment technology will not be retained for further consideration due
to the high percentage of fine-grained soil.
· 4.5.2 Stabilization/Solidification
Description -Stabilization/solidification is a proven technology. This method usually involves
the addition of stabilization agents to the soil to reduce the mobility of the contaminants.
Both physical and chemical bench scale tests must be conducted on the material to detennine the
efficiency of the process. The physical tests provide information on treatability and mixing
considerations. The chemical tests are related to the leaching properties of the soil following
treatment.
Several in-situ methods for mixing the materials are currently available commercially. These
include the following:
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
•
•
Geo-Con System
ENRECO System
Envirite System
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date; June 1994
Four different types of this technology will be screened for applicability:
• Cement-based stabilization
• Pozzolanic stabilization
• Thermoplastic stabilization
• Organic polymerization
Cement-Based Stabilization/Solidification
In this common stabilization/solidification process, waste materials are mixed with portland
cement or cement kiln dust. In the absence of liquid, water is added to ensure the hydration
reactions necessary for bonding the cement. Small amounts of fly ash, sodium silicate,
bentonite, or proprietary compounds are commonly added to the mixture to enhance the process.
The final product may vary from a granular, soil-like material to a cohesive solid. Literature I shows that the presence of organics greater than 20 percent by weight or semi-volatiles greater
than 10,000 ppm interfere with the bonding. At FCXS, organic levels are well below these
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values and should not interfere with bonding. This technology will be retained for further
consideration.
Pozzolanic Stabilization/Solidification
Pozzolanic stabilization/solidification uses siliceous materials to form a cementitious substance I when combined with lime or cement and water at ambient temperatures. The stabilization
I mechanism is the physical entrapment of the contaminant in the pozzolan matrix and, for some
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
compounds, chemical reaction/stabilization. Pozzolan materials include fly ash, pumice, lime
kiln dust, and blast furnace slag. The reaction is slower than cement and is typically not as
effective in reducing mobility. The solidified mass would be more subject to leaching than the
cementing based process; therefore, this process is eliminated from further consideration.
Thermoplastic Stabilization/Solidification
In this technology, the thermoplastic material, such as asphalt or polyethylene, does not react
with the encapsulating material. Instead, the thermoplastic material is used to bind the waste
constituents into a stabilized mass. For the contaminants at FCXS, complete immobilization
could be achieved; therefore, this process is retained for further consideration.
Organic Polymerization Stabilization/Solidification
In organic polymerization stabilization technology, a monomer is mixed with a catalyst and the
waste. A polymer is formed, which entraps the waste in a solid matrix. This technology has
been used primarily to stabilize radioactive waste. This technology is more costly than cement-
based processes, and has not been proven for hazardous waste; therefore it is eliminated from
further consideration.
A summary of available stabilization/solidification technologies is provided rn the following
table.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
STABILIZATION/SOLIDIFICATION TECHNOLOGY SCREENING
Technology/ Approach Status Reason
Cement-Based Process Retained Effective for contaminants found on-site. Would
require treatability study.
Pozzolanic Process Not Retained Not as effective as cementing in preventing leaching.
Thermoplastic Process Retained Effective for contaminants found on-site. Would require
treatability study.
Organic Polymerization Not Retained Not a proven technology for hazardous waste. Mainly
used for radioactive waste.
Effectiveness -Stabilization technology could effectively immobilize the waste materials present
at the FCXS. There is some residual risk of leaching contaminants, however, at low rates over
the long term. Stabilization does not destroy the contaminants, but is a valid method to reduce
exposure potential. Treatability studies are required to detem1ine the optimum mixtures of the
materials and leaching characteristics.
Implementability -All of the in-situ or ex-situ stabilization/solidification technologies could be
implemented.
Cost -The cost for stabilization/solidification is expected to be moderate.
Recommendation -Cement-based and thermoplastic stabilization will be retained for further
consideration.
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This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
4.5.3 Soil Flushing
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Description -Similar to soil washing, this technology refers to methods that mobilize and extract
contaminants from in-situ soils. Soil flushing is accomplished by use of water or an aqueous
chemical solution (i.e., water/surfactant or water/solvent) that is applied to the area of
contamination and then extracted for removal, recirculation, or on-site treatment and reinjection.
The soil washing process is usually accomplished by constructing infiltration galleries, injection
wells, or other delivery methods and by using groundwater extraction wells or interception
trenches for recovery. In some situations, the soil flushing system can be designed to function
as an in-situ bioreclamation system by providing nutrients to the subsurface soils.
Effectiveness -This technology is conceptually similar to soil washing (for excavated materials),
and similar extractants would likely be used to remove the various contaminants. As with soil
washing, multiple extraction steps may be required. These steps would be more difficult to
implement in-situ since the low soil permeability would make contact with the extractant more
difficult. This technology is best applied to soils that are located in the unsaturated or vadose
zone where the permeability is typically greater than I x 104 cm/sec and where there is a
shallow permeable overburden. For soils that are contaminated with a variety of hazardous
materials, the effectiveness is limited; pre-treatment and/or post-treatment may be necessary.
Soil flushing is best suited for soils with a sand content greater than 70 percent, which is not the
case at FCXS.
Implementability -A critical factor in all soil flushing operations is controlling flow through the
subsurface zone to ensure that all contaminated materials are adequately contacted and that
flushing solutions do not migrate where they are not being collected. The potential exists for
increasing mobility of contaminants, thereby enhancing contaminant migration; therefore, a
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June ~994
critical consideration in the use of this technology is the correct placement of recovery wells to
ensure complete capture of the flushing agent and to prevent the increased transport of mobilized
contaminants to the groundwater. In relatively homogeneous materials, flow control may be
possible; however, the degree of effective contact between solvent/extraction solutions and the
soil particles is more limited than when the soils are excavated and subsequently mixed with the
solution. In highly heterogeneous materials, adequate control of flow is difficult to achieve.
Cost -While this option may prove to be less expensive than excavation and washing, it is more
difficult to predict the overall length of the remediation effort. A protracted program would
likely diminish projected cost advantages.
Recommendation -Soil flushing will be retained for further consideration.
4.5.4 In-Situ Volatilization (ISV)
Description -ISV, or soil vapor extraction, is an established technology for in-place soil
treatment. It is primarily applicable to treatment of unsaturated, VOC-contaminated soils. ISV
treatment removes VOCs from the soil by mechanically drawing air through the soil pore spaces.
VOCs volatilize as the air moves through the soil. The VOC-laden air is then collected and
discharged or is treated, depending on the amount and types of contaminants present.
ISV is accomplished by installation of an array of vents in the contaminated portion of the
unsaturated (vadose) zone. These vents are essentially wells that are completed in the vadose
zone. The vents are manifolded to the suction side of air blowers (vacuum pumps), creating a
negative pressure in the vents and piping to draw air from the soil. Each vent is valved and can
be adjusted to the desired flow rate. Using these valves, an ISV system has the flexibility to
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This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
withdraw air from the most contaminated areas (thereby maximizing the mass removal rate) or
to operate at a lower mass emission rate as may be required by the emissions treatment system.
VOCs drawn from the soil matrix are discharged through the blower. Depending upon the
concentration of the VOCs in the air, emissions controls may be required. Vapor phase carbon
treatment of the air stream is a common emissions control technology, particularly for
chlorinated solvent contaminants.
Effectiveness -In order to operate efficiently, the unsaturated soil must have a penneability that
is sufficient to allow air movement through the soil. Porous soils are ideal for ISV remedial
treatment, although contaminant removal has been established in silty clay soils when high
vacuum pressures were applied.
At present, ISV is evaluated on the basis of the total amount of contaminant removed from the
soil. Although ISV applications are extremely successful in removal of VOCs, they do not
remove metals or most pesticides. Bench-and/or pilot-scale testing would be required to
determine the effectiveness of ISV treatment for the contaminants of concern.
Implementability -This technology would involve the installation of a number of "well vents"
across the site that must be manifolded to air blowers and subsequently an emission control
system. Soil excavation is not required. Since ISV removes only VOCs, this technology has
only limited benefit.
Cost -Cost for in-situ volatilization treatment is expected to be moderate.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
~action: 4
Revision: 1
Date: June 1994
Recommendation -The ISV process will not be retained for further consideration because
pesticides would not be effectively removed from the soil.
4.6 CHEMICAL TREA1MENT TECHNOLOGIES
The process options considered m this category are wet air oxidation, supercritical water
oxidation, and dechlorination.
4.6.1 Wet Air Oxidation
Description -Wet air oxidation CW AO) refers to a high-temperature, high-pressure oxidation of
dissolved or finely divided organic and inorganic constituents in an aqueous medium. High
pressure increases the solubility of oxygen in water, which helps drive the oxidation reaction.
The oxidation reactions are exothermic, which makes the process thermally self-sustaining as
long as the organic content of the process stream is sufficiently high.
After the wastes are oxidized, the pressure is reduced and the effluent is discharged to a
separator where liquid and gaseous streams are separated. Both of these streams may require
additional treatment before discharge.
Effectiveness -Wet air oxidation is potentially applicable to soil in a slurry fonn, although it
has been tested and applied primarily to sludges and concentrated wastewater. Size classification
for soils would be required to remove oversized and large size fractions. Wet air oxidation is
not appropriate to unmoistened soil or to floating product because it requires aqueous
environment. The concentration of organics in the soil may be too dilute to sustain the oxidation
reaction.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Implementability -Treatability testing would be required to determine the effectiveness of this I technology to soil slurries and to the contaminants of concern at the site. Generally, wet air
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oxidation is not justified for small quantities due to the relatively high capital investment.
Materials of construction are stainless steel or more costly alloys.
Cost -The cost for this treatment is expected to be relatively high.
Recommendation -Wet air oxidation will not be retained for further consideration as a treatment
for soil because the concentration of organics may be too low to be applicable.
4.6.2 Supercritical Water Oxidation
Description -Supercritical water oxidation, like wet air oxidation, is a technology originally
developed as a treatment for sludges and high-concentration organic wastewater, which may be
. used to treat soil slurries.
The distinction between supercritical water oxidation and W AO is that the fonner relies on the
improved solubility of oxygen and organics in water in its supercritical state rather than high
pressure as a means of driving the oxidation reaction.
Effectiveness -As with W AO, a minimum strength organic stream, reportedly as low as 20,000
ppm, is required to make the oxidation reaction self-sustaining.
Implementability -Treatability testing would be required to determine the effectiveness of this I technology to soil slurries and to the organic contaminants of concern at the site.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Cost -The cost for the treatment is expected to be relatively high.
Recommendation -Supercritical water oxidation will not be retained for further consideration
because its applicability to soil slurries is uncertain.
4.6.3 Dechlorination
Description -Dechlorination treatment involves the addition of chemical reagents to break apart
or structurally rearrange chlorinated compounds. Dechlorination can be effected by adding alkali
with polyethylene glycol (APEG) or by adding acid with a metal catalyst (such as copper or
nickel). APEG soil treatment was originally developed to treat soils containing chlorinated
biphenyls, dioxins, and dibenzofurans.
After reaction with the reagent, excess solution is decanted and the soils are washed two or three
times with water. The decontaminated soils are then discharged from the process for disposal
on-or off-site. Subsequent treatment of the washwater may be required.
Another dechlorination process known as Base Catalyzed Decomposition (BCD) has been
demonstrated by the U.S. EPA in laboratory scale to destroy halogenated contaminants. The
process was developed by the Risk Reduction Engineering Laboratory (RREL) of U.S. EPA.
This process results in complete dehalogenation whereby all halogen ions are replaced by
hydrogen radicals.
ETG Environmental and SoilTech ATP Systems, Inc. have been licensed and commercialized
the BCD process for use in conjunction with thermal desorption of soils contaminated with
dioxins, polychlorinated biphenyls (PCBs), pentachlorophenol (PCP), and pesticides/herbicides.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA lt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
When used with thermal desorption, condensed liquids from the off-gas are recovered and
treated within a liquid reactor capable of heating up to 650°F. Following treatment, the liquid
is filtered to remove solids and polished by carbon adsorption units.
Effectiveness -The chemical dechlorination of soils contaminated with chlorinated aromatics has
been demonstrated at the laboratory scale and in field tests, but has not been shown in full-scale
operation. Initial findings show significant reductions in contaminant levels during controlled
experiments. The BCD process in conjunction with the ETG Therm,O-Detox system was
successfully demonstrated at the Koppers Superfund Site in Morrisville, North Carolina, under
the Superfund Innovative Technology Evaluation (SITE) Program.
Implementability -The BCD process is currently available by ETG Environmental and SoilTech.
Cost -The cost for the system is expected to be moderate.
Recommendation -The BCD treatment method will be retained for further evaluation in
conjunction with thermal desorption for treatment of pesticides and PCP in the soil at FCXS.
4.7 THERMAL TREATMENT TECHNOLOGIES
The process options being considered in this category are incineration, thennal desorption, and
vitrification.
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This docu.ment was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
4.7.1 Incineration
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Description -Incineration represents an applicable technology for use in a remedial action
program where the waste stream is predominantly organic. Incineration designs are generally
complex and are heavily instmmented for control and monitoring. Incinerators destroy the
hazardous constituents of the waste as well as reduce somewhat the disposal volume.
Environmental concerns include off-gases from the incinerator, such as sulfur dioxide and
sulfuric acid, and to hazardous residuals, such as heavy metals.
Incinerators may be categorized by the nature of the wastes to be destroyed, either solid, liquid,
sludge, or gas. Incineration systems can be adapted to burn more than one waste type at a time.
Both stationary and mobile systems have been used.
Generally, three systems are applicable for the incineration of hazardous wastes:
• Rotary kiln
• Multiple hearth
• Fluidized bed
Rotary Kiln
A rotary kiln is comprised of a cylindrical, refractory-lined steel shell, supported at two or more
points. The kiln is sloped gently (usually less than 3 percent) and is rotated slowly (usually less
than 2 rpm) using an externally mounted gear. The internal surface of the kiln may be smooth,
or it may contain various types of internal plates or ridges. Longitudinal ridges tend to lift and
spill the material; circumferential ridges act as dams to detain the material to achieve proper
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revisio·n: 1
Date: June 1994
residence times. A senes of baffles improves the contact of the material with the air. The
rotary kiln has been used extensively for incineration of hazardous wastes.
Mobile incinerator units are also available for hazardous wastes. Mobile rotary kilns are
available for on-site treatment with processing rates ranging from 0.6 to 5 tons/hour. For higher
processing rates, on-site treatment could be accomplished by using multiple incinerators or
construction of a dedicated incineration unit.
There are several mobile incinerators capable of processing the soil at FCXS. An emissions
monitoring program.would be mandatory and ambient air quality monitoring could be required.
Off-site commercial incinerator facilities are available. Incineration costs, however, are quite
high for wastes that produce large amounts of ash, wastes that have a high sulfur content, and
bulk solid wastes because of related handling problems and costly air pollution control devices.
In addition, many of these facilities are operating at near capacity and are reluctant to accept
new quantities of large volume, noncombustible (soil) wastes. Commercial incinerators are not
typically equipped to feed soils in bulk form and it would have to be repacked into fiber drums.
Multiple Hearth
The multiple hearth furnace is the most widely used incinerator for municipal sewage sludges
and is quite adaptable to the incineration of hazardous waste sludges. A typical unit consists of
a vertical cylindrical shell containing between 4 and 12 firebrick hearths. A slowly rotating
hollow shaft (rate of 0.5 to 1.5 rpm) with attached rabble am1s mixes and carries the material I through the unit during incineration. Cool air is fired up through the shaft, wanned through
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
conduction and convection, to feed the incinerator. This type of incinerator is not as versatile
as a rotary kiln and is not generally available or in use for soil incineration.
Fluidized Bed
The fluidized bed incinerator incorporates high burning efficiencies with short residence times.
The unit is comprised of a vertical, cylindrical, refractory-lined vessel with a perforated
supporting grid at its base. In the lower section, a layer of sand is fluidized using a forced
heating air system. Sludge is injected and incinerated. The fluidized sand enhances rapid heat
and mass transfer and creates uniform vessel temperatures and short incinerator residence times.
This technology is not as widely used or available as rotary kiln for soil incineration.
Effectiveness -Incineration technology has been proven to satisfy relevant RCRA regulatory
requirements for organic compound destruction, including pesticides. Incineration technologies
do not destroy heavy metals; therefore, metals concentration in incinerator residuals (gas and
ash) must be considered.
Implementability -Incineration technology could be readily implemented by transporting
contaminated soil to an off-site incineration facility. Mobile incineration units are also available,
but some site preparation would be required. Local resistance to an on-site incinerator may also
be encountered. A trial burn would be necessary to demonstrate the RCRA destruction removal
efficiency (DRE). During the trial burn, air permitting would be necessary for incinerator
emissions.
Cost -Costs for incineration are expected to be high.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Recommendation -Incineration will be retained for further consideration.
4.7.2 Thermal Desorption
Description -Thermal desorption process is a proven technology for removing volatile organic
compounds from soil or sediment. The heart of this treatment system is the thermal processor,
an indirect heat exchanger that is used to heat and consequently dry the contaminated materials
which volatilizes the organic compounds and water. Temperatures up to 450°F are typically
used for desorption of VOCs and PAHs, while temperatures of up to l000°F or more may be
required for removal of P AHs, PCBs, and pesticides. Thermal desorption of a particular
compound occurs when the boiling point is reached and the total vapor pressure equals I
atmosphere.
The volatilized emissions can either be destroyed by a secondary high temperature combustor,
absorbed onto activated carbon, or condensed. Condensed off-gases can be sent off-site for
treatment or treated on-site with the BCD dechlorination process described earlier. Treated soils
are typically returned to the ground on-site.
Effectiveness -Thermal desorption has been successfully applied to a number of volatile and
semivolatile compounds, including some pesticides. Due to their relative instability, pesticides
are thought to be degraded rather than volatilized by the heat. This them1al process was
demonstrated with BCD at the Koppers Superfund Site in Morrisville, North Carolina under the
SITE program. Preliminary results indicate that the demonstration was successful in treating
PCP, dioxins, and furans.
Implementability -Thermal desorption units are readily available from a number of vendors.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Cost -The costs of this technology are moderate relative to other types of soil treatment.
Recommendation -Thermal desorption will be retained for further consideration because it has
been successful in treating contaminated soils similar to those at the FCXS site.
4. 7 .3 Vitrification
Description -In-situ vitrification is a process in which in-place soils are converted to a durable,
glass-like material by heating to extreme temperatures. This conversion is achieved by passing
an electrical current through soils that produces temperatures between 1,600 and 2,000 ° C.
The basic design of an in-situ vitrification system consists of four electrodes driven into the soil
in a square configuration. The electrodes can be constructed of either graphiie or molybdenum
with spacings up to 20 feet. When an electric current is passed through these electrodes, the
temperature of the soil between them increases until the soil vitrifies. The maximum achievable
melt depth varies inversely with increasing electrode spacing.
In the process, most of the organic constituents in the soil are pyrolyzed in the melt or migrate
to the surface, where they combust in the presence of oxygen. The off-gases are collected in
a hood and directed to an off-gas cleaning train. Inorganic contaminants in the soil are
effectively bound in the solidified glass. The bulk leach rate of the vitrified mass is reported
to be significantly slower than in granite, marble, or bottle glass.
Effectiveness -This technology has been developed to large-scale and is ready for commercial
deployment, but it does not have a significant commercial experience base. Large-scale testing
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
has included the successful treatment of soils contaminated with heavy metals, liquid and solid
organic compounds, and radioactive materials.
Implementability -Of primary concern in implementing this technology is the potential to initiate
an explosion due to its energy-intensive nature. Because this technology is implemented in-situ,
all of the affected and "to-be-treated" soils cannot be inspected and blended to ensure that
concentrated "hot spots" of contaminants do not present a safety hazard. With most other in-situ
technologies, this would not be a concern because they are not as energy-intensive.
Battelle Memorial Institute has obtained exclusive rights to the application of in-situ vitrification
and in turn has exclusively sublicensed Geosafe Corporation for commercial deployment of the
technology. In July 199 I, Geosafe temporarily suspended full-scale commercial applications
after a fire during an operational acceptance test. The fue occurred when molten glass splattered
and hit the newly designed hood, which consisted of a ceramic and glass-layered fabric coated
with silicone. Geosafe plans to resume large-scale operations with a metal hood but has. not
indicated when the technology will be placed back on the market. The large-scale unit requires
a 12,500 or 13,800-V power source.
Cost -The cost for this technology is expected to be high primarily due to energy consumption
and the uncertain status of this technology at the present time.
Recommendation -In-situ vitrification will not be considered because of safety concerns
involving potential explosions and the uncertain status of this technology at the present time.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
4.8 BIOLOGICAL TREATMENT TECHNOLOGIES
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
The biological treatment process options being considered are bioremediation/bioreclamation and
bioslurry.
4.8.1 Bioremediation/Bioreclamation {In-Situ)
Description -In-situ biological treatment, also referred to as bioremediation or bioreclamation,
is a technique for treating contaminated soils and groundwater in place by microbial degradation.
Treatment is accomplished by the addition of oxygen and nutrients to soil and groundwater to
enhance the natural biodegradation of organic compounds by microorganisms, resulting in the
breakdown and detoxification of the organic contaminants. These microorganisms can be
naturally occurring, specially adapted, or genetically engineered.
Nutrients and an oxygen source are delivered to the soils through injection wells or an
infiltration system. The groundwater (sometimes accompanied by surfactants) is often used to
carry the nutrients through the treatment zone by means of groundwater recirculation and
collection technologies.
Effectiveness -Bioreclamation has been successfully used in tests on materials contaminated
with pesticides and acid extractable compounds; however, bioreclamation is sensitive to a
number of environmental factors, including heterogeneous subsurface conditions, availability of
trace nutrients, oxygen concentration, redox potential, pH, degree of water saturation, and
temperature. These factors would have to be monitored and controlled during operation. The I specific types of pesticides at FCXS are not highly water soluble; therefore, separation from the
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
soil media would be difficult. It is critical that the contaminants be separated for effective
degradation.
Implementability -Bench or pilot-scale tests would be required to determine the feasibility of
bioreclamation for organics under site conditions and to detennine design and operating
parameters. As with soil flushing, controlling flow through the subsurface zone is essential.
Recovery wells must be carefully placed to ensure complete capture of the enriched/treated
groundwater and to prevent transport of potentially toxic degradation products beyond the
treatment zone.
In a manner similar to soil flushing technologies, in-situ biological techniques may result in an
increased contaminant mobility and a subsequent increase in the rate of contaminant migration.
Cost -Cost of this technology is expected to be relatively high due to extensive treatability
studies required.
Recommendation -The low water solubility of the pesticides at FCXS will make this technology
ineffective; therefore, in-situ bioreclamation will not be retained for further consideration.
4.8.2 Bioslurry
Description -Bioslurry treatment is a technique for treating contaminated soils in a reactor.
Treatment is accomplished by the addition of oxygen and nutrients to soil to enhance the natural
biodegradation of organic compounds by microorganisms, resulting in the breakdown and
detoxification of the organic contaminants. These microorganisms can be naturally occurring,
specially adapted, or genetically engineered.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Nutrients and, if necessary, oxygen are delivered to the soils through injection wells or an
infiltration system. Water sometimes accompanied by surfactants is used to carry the nutrients.
Effectiveness -Review of the literature indicates that bioslurry has been successfully used in
tests on materials contaminated with pesticides and acid extractable compounds. The process
is sensitive to a number of environmental factors, including availability of trace nutrients,
oxygen concentration, redox potential, pH, degree of water saturation, and temperature. These
factors must be monitored and controlled during operation. The types of pesticides at FCXS are
not highly water soluble; therefore, separation from the soil media would be difficult. It is
critical that the contaminants be separated for effective degradation.
Implementability -Bench or pilot-scale tests would be required to determine the feasibility of
the process and to determine design and operating parameters. Unlike in-situ bioremediation,
bioslurry treatment would require the excavation of contaminated soil.
Cost -Cost of this technology is expected to be relatively high due to extensive treatability
studies required.
Recommendation -Bioslurry will not be retained for further consideration because the low water
solubility of the pesticides at FCXS make the technology ineffective.
4.9 DISPOSAL OPTIONS
The technologies discussed include disposal of contaminated materials in either an on-site landfill
or an off-site landfill. Under some off-site technologies, such as incineration, ultimate disposal
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This document was prepared by Roy F, Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
is handled by the treatment vendor. Treated soils that meet the land ban restrictions and are
delisted by EPA may be backfilled on-site without constructing a lined landfill.
4.9.1 On-Site Landfill
Description -Disposal of contaminated soil initially involves excavation and staging in a secure
area. Construction of an on-site landfill would require a double-liner system with leak detection
and leachate collection systems. Following placement of the contaminated soil in the cell, a
RCRA-Ievel closure would be required, including multi-layer cap installation and maintenance.
The depth of the landfill would be limited to allow an adequate buffer zone between the base of
the landfill and the water table.
Effectiveness -On-site disposal requires excavation of the contaminated soils currently estimated
to be a minimum of 6,945 cubic yards. An on-site landfill would be constructed and the soil
placed within the ceIL The overall risk to the public and the environment would be minimal.
Implementability -RCRA landfill would be difficult, if not impossible, to construct on the FCXS
property, which covers only 5.5 acres.
Cost -Capital costs for on-site landfill construction meeting RCRA standards would be relatively
high. Additional expenses would be incurred for handling and treatment of leachate.
Recommendation -The construction of an on-site RCRA landfill alternative is eliminated from
further consideration due to available space and logistical considerations.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. Jt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
4.9.2 Off-Site Landfill
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994 .
Description -Under this technology, contaminated soil is excavated and transported to a
permitted RCRA Subtitle C landfill. The landfill must meet the RCRA requirements for
hazardous waste to effectively contain the wastes and provide long-term security against
additional groundwater contamination or direct exposure to sensitive populations.
Effectiveness -This is a proven remedial approach and the overall risk to the public and the
environment may be minimal if properly executed.
Implementability-Off-site disposal would require considerable materials handling. Additionally,
several factors would need to be addressed including sufficient characterization of the waste to
obtain acceptance at a landfill, the location of a suitable landfill, and other RCRA and DOT
requirements. Some of the soils may contain contaminants at concentrations exceeding the LDR
limits and therefore cannot be landfilled without prior treatment. TCLP testing during the
remedial design will confirm the toxicity level.
Cost -Costs for disposal in an off-site landfill would be expected to be moderate. For soils that
require treatment under the LDRs, the costs would be higher.
Recommendation -Disposal at an appropriate off-site landfill will be retained for further
consideration.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
4.10 SUMMARY
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 4
Revision: 1
Date: June 1994
Based on the preceding evaluation of effectiveness, implementability and costs, recommendations
were made concerning retention of technologies. The following technologies have been retained
for further consideration for remediation of soil:
No Action (Retained as required by NCP)
Institutional Controls -Deed Restriction
Containment Technologies -Capping (Paving)
Removal Technologies -Excavation
Treatment Technologies
• Stabilization (Cement and Thermoplastic)
• Soil Flushing
• Dechlorination
• Incineration
• Thermal Desorption
Biological Treatment Technologies -None
Disposal Technologies -Off-site Landfill
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This document was prepared by Roy F. Weston, lnc., expressly for EPA. Jt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
SECTION 5
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
Revision: 1
Date: June 1994
DEVELOPMENT AND SCREENING OF REMEDIAL ACTION ALTERNATIVES
5.1 INTRODUCTION
Remedial action alternatives were formulated to address the soil contamination associated with
FCXS. Section 4, "Identification and Screening of Remedial Technologies," provided a
preliminary evaluation of each potentially applicable remedial technology, considering the
effectiveness of the technology in obtaining the remedial action objectives, implementability, and
relative cost. Based on this preliminary screening, selected technologies were retained and
combined into remedial alternatives as presented in this section.
The purpose of the alternative development process is to produce remedial action alternatives
which provide a range of approaches and effectiveness; therefore, the alternatives vary in the
degree of remediation they provide. Various remediation categories have been identified by the
NCP and modified according to the recent SARA guidelines to specify a range of remediation
levels. These categories are as follows:
• No action or limited action alternatives (which may include minimal actions such
as access restrictions and monitoring activities).
•
•
Alternatives using a containment option involving little or no treatment of site
source contamination.
Alternatives that meet CERCLA goals (preventing or limiting present or future
migration of hazardous substances and protecting public health and the
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This document was prepared by Roy F, Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
Revision: 1
Date: June 1994
environment) and attain ARARs for Federal and state public health and
environmental standards, guidance, and advisories.
Alternatives specifying off-site destruction, treatment, or secure disposal of
hazardous substances at a facility approved under RCRA. Such a facility must
also be in compliance with all other applicable EPA standards.
A discussion of the alternatives selected for detailed evaluation at the site are presented later in
this section.
5.2 SUMMARY OF REMEDIAL LEVELS
The overall objective of the remediation process at the site is to protect public health and the
environment.
The specific objectives of soil remediation at FCXS are:
• To. achieve remediation levels for the contaminants of concern.
• To mitigate potential risk to human health posed by contact with contaminated
soil.
The soil remediation levels were presented in Section 3. These levels are summarized in Table
5-1 for soil contaminants. The development of remedial alternatives is presented in the
following subsections.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Total Pesticides'
Pentachlorophenol
Dioxin
Table 5-1
Soil Remediation Levels
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
· Revision: 1
Date: June 1994
Remedial Goal (mg/kg)
1.0
3.2
0.001
'Includes gamma-BHC (Lindane), endrin, dieldrin, chlordane, DDT, and DDD.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
Revision: 1
Date: June 1994
5.3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
Technologies that were not screened out have been assembled into remedial alternatives, which
are presented in Table 5-2. A total of 24 alternatives were developed by combining the various
treatment options. Each of the alternatives were evaluated in relation to one another based on
-effectiveness, implementability, and cost. This screening process as well as the outcome of the
screening is also presented in Table 5-2.
The six soil alternatives that will be further evaluated are as follows:
• Alternative 1 -No Action -This alternative consists of no remedial action.
•
•
•
•
•
Alternative 2 -Limited Action/Capping -This alternative consists of property deed
restrictions and paving of contaminated areas not already covered.
Alternative 3 -Building Removal/Capping -The buildings are removed and
contaminated areas are capped. Property deed restrictions would be imposed.
Alternative 4 -Excavation, Thennal Desorption with BCD -The buildings are
removed, contaminated soil is excavated and treated on-site using medium-
temperature thermal desorption with base catalyzed decomposition. The treated
soil is backfilled on-site.
Alternative 5 -Excavation, Thenna/ Desorption -The buildings are removed and
contaminated soil is excavated and treated on-site using thermal desorption. The
treated soil is backfilled on-site.
Alternative 6 -Excavation, Off-Site incineration -The buildings are removed .
Contaminated soil is excavated, transported off-site for incineration at an approved
RCRA facility.
Each of these alternatives is evaluated in Section 6.
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This document was prepared by Roy F. Weston, lnc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Soil Alternatives
No Ac~ion
Limited Action -Deed Restriction,
Capping
Building Demolition with Capping
Excavation, On-Site
Stabilization/Solidification
Soil Flushing
Excavation, Dechlorination
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
Revision: 1
Date: J_une 1994
Table 5-2
Screening of Alternatives
Evaluation of Effectiveness, Screening Decision
Implementability, and Cost
Soil contact risks are already low; however, Considered in detailed
leaching of contaminants from uncovered evaluation as
areas into groundwater would not be Alternative I.
mitigated. NCP requires evaluation of No
Action alternative.
Effective at mitigating potential future Considered in detailed
exposures as well as leaching to groundwater. evaluation as
Capping easily implemented with asphalt Alternative 2.
paving materials and equipment at low cost.
More effective than Alternative 2 in reducing Considered in detailed
future exposures. Requires additional safety evaluation as
measures to demolish the buildings. Capping Alternative 3.
would be effective at mitigating leaching of
contaminants into groundwater. Still need
deed restrictions to prohibit future excavation.
Easily implemented at moderate cost.
Less effective than other treatment Screened out
technologies. Requires bench-scale studies to
determine the optimum binder materials.
Does not reduce or eliminate the
contaminants. Binder additives tend to
significantly increase treated soils volume.
Similarly implementable as other treatment
technologies.
Less effective than and similarly Screened out
implementable as other treatment
technologies. Moderate costs.
Effective for pesticides and PCP. Base Considered in detailed
Catalyzed Decomposition (BCD) demonstrated evaluation as
by U.S. EPA in laboratory to destroy Alternative 4 with
halogenated contaminants. Successfully thermal desorption.
demonstrated with thermal desorption under
SITE Program.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Soil Alternatives
Excavation, Off-Site Incineration
Excavation, On-Site Incineration
Excavation, Thermal Desorption
Excavation, Off-Site Landfill
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Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 5
Revision: 1
Date: June 1994
Table 5-2 (Continued)
Screening of Alternatives
Evaluation of Effectiveness, Screening Decision
Implementability, and Cost
Expected to be effective on all contaminants. Considered in detailed
Implementation not too difficult. Highest cost evaluation as
among all treatment technologies. Alternative 6.
Expected to be effective on all contaminants. Screened out
Implementation difficult due to expected
resistance from state regulators and local
citizens. High costs, but not as high as off-
site incineration.
Innovative technology demonstrated with BCD Considered in detailed
process under the SITE Program. At evaluation as part of
temperatures up to 950°F, it is expected to Alternative 4 and
desorb site contaminants. Moderate costs. separately as
Alternative 5.
Not expected to meet land ban restrictions Screened out.
including LDR treatment and disposal
standards without prior treatment. Relatively
easy to implement. Costs are lower than for
treatment technologies, if the soil could be
accepted.
5-6
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
SECTION 6
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
6.1 INTRODUCTION
Based on the initial screening and subsequent evaluation of remedial technologies, six
alternatives for soil remediation have been designated for detailed analysis. The detailed analysis
of alternatives consists of the analysis and presentation of relevant inforniation required to allow
decision makers to select a site remedy .. In this detailed analysis, each of the six required
alternatives under consideration is evaluated against the seven evaluation criteria. The results
of this assessment are then used to make comparisons among the various alternatives presented
in Subsection 6.2.
A detailed analysis of alternatives consists of the following components:
• Definition of each alternative with respect to the specific measures to be
taken, the volumes or areas of contaminated media to be addressed, the
technologies to be used, and any performance requirements associated
with those technologies.
•
•
An assessment and a summary of each alternative against the seven
evaluation criteria.
A comparative analysis among the alternatives to assess the relative
perfonnance of each alternative with respect to each evaluation criterion.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.2 EVALUATION CRITERIA
In accordance with NCP and EPA Superfund guidance documents, the following seven criteria
were utilized for evaluation and comparison of each of the developed site alternatives that were
__ selected for detailed analysis:
•
•
•
•
•
•
•
Compliance with ARARs .
Short-term effectiveness .
Long-term effectiveness and permanence .
Overall protection of human health and the environment.
Reduction of toxicity, mobility, and volume of contaminants .
Implementability .
Cost.
Two criteria (compliance with ARARs and overall protection of human health and the
environment) are categorized as threshold criteria in that each alternative must meet them ( or
a variance must be obtained). The other five criteria are categorized as the primary criteria
upon which the analysis is based.
All seven criteria are further described below, while the detailed analysis of each remedial
alternative is presented in subsequent subsections. Two additional criteria, state acceptance and
community acceptance, will be addressed in the Record of Decision after the FS has_ been
finalized.
6.2.1 Compliance with Applicable or Relevant and Appropriate Requirements
This criterion is used to detennine whether and how each alternative complies with ARARs, as
presented in Section 2 of this report. The chemical, location, and action-specific requirements
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
are discussed along with any other appropriate criteria, advisories, and guidance as they apply
to each alternative.
6.2.2 Short-Term Effectiveness
This evaluation criterion involves consideration of the short-tenn effectiveness of the alternative
during construction and implementation. The evaluation focuses on the protection of the
community and the on-site personnel during the implementation of remedial measures, potential
human health and environmental impacts, and the time required to achieve remedial response
objectives.
6.2.3 Long-Term Effectiveness and Permanence
This evaluation criterion involves consideration of the long-tenn effectiveness and pernianence
of the alternative once it has been implemented. The evaluation focuses on defining the extent
and effectiveness (adequacy and reliability) of the controls that may be required to manage the
residual risk remaining from untreated waste and/or untreated residues. Alternatives that afford
the highest degrees of long-term effectiveness and permanence are those that leave little or no
waste remaining at the site such that long-term maintenance and monitoring are unnecessary and
reliance on institutional controls is minimized.
6.2.4 Overall Protection of Human Health and the Environment
This evaluation criterion involves consideration of the overall protection of human health and
the environment. The overall assessment of protection draws on the assessment conducted for
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This document was prepared by Roy F. Weston, lnc., expressly for EPA It shall not be released or disclosed, ln whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
other evaluation criteria, particularly long-tenn effectiveness and pennanence, short-tenn
effectiveness, and compliance with ARARs.
Evaluation of the overall protectiveness of an alternative focuses on achievement of remedial
_action objectives and how risks posed through potential exposure routes are eliminated, reduced,
or controlled through treatment, engineering, or institutional controls. This evaluation also
allows for consideration of whether an alternative poses any unacceptable short-tenn or cross-
media impacts.
6.2.5 Reduction of Toxicity. Mobility. and Volume of Contaminants
Consideration of this evaluation criterion is a result of the regulatory preference for selecting
remedial actions that pennanently and significantly reduce the toxicity, mobility, and volume of
the contaminants and associated media.
The following factors are considered in this evaluation:
•
•
•
•
•
The treatment process and materials to be treated .
The amount of hazardous materials to be treated .
The degree of expected reduction in mobility, toxicity, or volume .
The degree to which treatment will be irreversible .
The type and quantity of residuals that remain after treatment.
6.2.6 Implementability
This criterion establishes the technical and administrative feasibility of implementing an
alternative. Technical aspects evaluated for each alternative include: ability to constrnct and
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
operate the technologies involved; reliability of the technologies involved; ease of undertaking
additional remedial action; and ability to monitor the effectiveness of the remedy after
completion of the activities. · Administrative concerns include establishing contact with
appropriate agencies to implement remedial actions (e.g., obtaining approval for construction
_and op.eration of a treatment unit, and coordination with various agencies). Availability of
materials and services needed is another factor considered, specifically with respect to the
availability of treatment, storage and disposal facilities, equipment and operators, and
prospective technologies.
6.2.7 Cost
A remedial program must be implemented and operated in a cost-effective manner as well as
mitigate the environmental and human health concerns at the site. In considering the cost-
effectiveness of the various alternatives, the following categories are evaluated:
• Capital costs -These costs include direct (construction) and indirect (non-
•
construction and overhead) costs. Direct costs include expenditures for
equipment, labor, and materials necessary to install remedial actions. Indirect
costs may be incurred for engineering treatability testing, pennitting, construction
management, or other services not directly involved with installation of remedial
alternatives, but necessary for completion of the activity.
Operation and Maintenance (O&M) Costs -These costs include post-construction
expenditures incurred to ensure effective implementation of the alternative and
monitoring expenditures. Such costs may include, but are not limited to,
operating labor, maintenance materials and labor, rental equipment, auxiliary
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
materials (e.g., chemicals), energy (fuel and electricity), disposal of residues,
administrative and insurance costs, sampling and analytical work, and pennit
compliance monitoring.
For soil remediation that can be completed m less than 12 months, operating costs are
incorporated into the capital costs.
A present worth analysis is utilized for the cost evaluation utilizing a discount rate of 5 % as
recommended under the Superfund program. The present worth method of evaluation transfonns
future expenditures such as annual O&M costs or five-year review costs into equivalent dollars
now. The present worth of these costs is always less than the future worth when the discount
rate is greater than zero. For alternatives without annual O&M costs, the present worth is the
actual capital outlay to perform the remedial alternative. Cost sensitivity concerns are identified
and discussed as required for each alternative.
The costs presented in this report are estimates in the range of -30 percent to +50 percent. I These costs are based on a variety of information, including estimates from suppliers,
construction unit costs, vendor information, conventional cost estimating guides, and prior I expenence. The feasibility study-level cost estimates shown have been prepared for guidance
in project evaluation comparison, and selection based in the information available at the time of I the estimate. The costs of the selected alternative can be refined to a greater level of accuracy
during the remedial design. The actual costs of the project will depend on true labor and
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material costs, actual site conditions at the time of implementation, and other variable factors.
Most of these cost uncertainties would similarly affect all of the alternatives presented in this
feasibility study report. Therefore, alternative costs are comparable.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
The capital cost estimates do not include the cost of remedial actions already completed or
underway. The cost of state or EPA oversight of this project has not been included.
6.3 ALTERNATIVE 1-NO ACTION
6.3.1 Description of Alternative
Under the No Action alternative, no remedial actions would be implemented. Contaminated soil
would be left in place without treatment as a source for migration of the contaminants of concern
into groundwater. Any reduction in contaminant concentrations in the groundwater or soil would
be only due to natural dispersion, attenuation, and degradation processes.
6.3.2 Compliance with ARARs
There are no ARARs for contaminant levels in soil. Location-specific and action-specific
ARARs are not applicable as there are no remedial actions associated with this alternative. The
alternative will only be evaluated to determine if it is protective of human health and the
environment.
6.3.3 Short-Term Effectiveness
The No Action alternative will not mitigate on-site contamination on a short-tenn basis. This
alternative may achieve on-site remedial objectives only after an indefinite period of time and
exclusively through natural processes. The potential environmental impacts associated with the
contaminated soil would remain unaddressed during that period. Given the low rates of
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This document was prepared by Roy F. Weston, 1nc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
degradation and dispersion for the detected contaminants, little reduction in contaminant
concentrations can be expected in the short-term.
6.3.4 Long-Tenn Effectiveness and Permanence
This criterion addresses the results of a remedial action in terms of the risk remaining at the site
after remedial action objectives have been met. Any reduction in concentrations in the long-term
will be due to natural dispersion, attenuation, and degradation processes. It is questionable
whether remedial action objectives can be met through natural processes in the foreseeable
future; therefore, the chemical concentrations remaining at the site after many years may
continue to leach contaminants into the groundwater. Because this alternative would leave
hazardous substances on-site, six policy five-year reviews would be performed for a period of
30 years to assess the site with respect to protection of human health and the environment.
6.3.5 Overall Protection of Human Health and the Environment
Risks posed by the continued presence of contaminants in the soil will not be addressed.
Potential exposure to soil is not mitigated; therefore, this alternative does not achieve the desired
remediation goals, and is not protective of human health. Since no restrictions on future site use
are imposed, the potential remains for development of the site that might cause exposure to
contaminated soil surrounding the warehouse as well as beneath the warehouse if it were
removed. The contaminated soil would also continue to act as a source of contamination to
groundwater.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.3.6 Reduction of Toxicity, Mobility, or Volume of Contaminants
The No Action alternative provides no active treatment process. As a result, contaminants will
degrade only by passive, natural processes. Toxicity and mobility of the contaminated material
_ may remain at their present levels for extended periods of time. Further, the affected soil may
increase the overall groundwater contamination and enlarge the plume.
6.3. 7 Implementability
The No Action alternative can be easily implemented as it does not require any present or future
efforts. Acceptance from the regulatory agencies and the community will be the only issues
restricting implementation.
6.3.8 Cost
There are no capital costs associated with the No Action alternative. Costs to perfonn reviews
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every five years estimated to cost $20,000 each results in a present worth cost of $55,640.
6.4 ALTERNATIVE 2 -LIMITED ACTION/CAPPING
6.4.1 Description
Under this alternative:
• The buildings and pavement are left in place;
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
•
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Areas of contaminated soil not already covered by buildings will be capped (with
pavement);
• The property deed will be amended to prohibit future uses of the site that would
uncover or expose contaminated soil beneath the buildings and pavement and
place limitations on the future use of on-site groundwater.
Soil areas exceeding the cleanup goals would be paved with a 4-inch layer of bituminous
concrete (asphalt). This type of capping would be effective at the FCXS site in eliminating
direct contact with and leaching of contaminants. Groundwater monitoring would be included I as part of the selected groundwater alternative.
I Prior to paving, the following general site preparation is necessary:
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Survey the site to mark the limits of the area to be paved .
Assess the warehouse in Area 3 to detern1ine the need for decontamination .
Prepare an area for decontamination of equipment and any warehouse debris .
Construct a concrete pad with curbs and sump fqr the collection of
decontamination water. The waste water would be stored and tested prior to
discharge.
Clear and grub all other areas requiring paving .
Paving will be performed with standard roadway construction equipment consisting mainly of
a paving machine. The asphalt would be prepared in a batch mixing plant off-site and
transported to the site in bulk dump trucks. The asphalt will then be transferred to the paving
machine for placement at the appropriate thickness. A 4-inch layer of asphalt would consist of
a 2-inch base cover followed by a 2-inch top course. Each course will be compacted with a steel
roller. Dust suppression by wetting the soil would be performed as necessary. All equipment
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date; June 1994
will be required to be decontaminated prior to moving from the site. Soil sample locations
exceeding cleanup goals are shown on Figure 6-1 along with the respective area designations.
Table 6-1 lists these sample locations and contaminant concentrations exceeding the cleanup
levels. Since Area 3 is covered by the warehouse, only the contaminated areas in Areas 1 and
-2 will require paving. This area covers approximately 17,300 square feet. Figure 6-2 indicates
the areas to be paved. The paved areas would adequately cover the necessary locations and
provide a continuous paved area requiring less maintenance than spot patching each sample
location. The areas along the railroad spur near samples FS-224, FS-225, FS-226, and FS-228
will be asphalted with gaps at the existing tracks.
This alternative will render the site useful for continued industrial activity. Maintenance of the
paved areas would be necessary. The frequency would depend upon the amount of traffic in the
area.
6.4.2 Compliance with ARARs
No chemical-specific ARARs have been directly established for the contaminant levels in soil.
The remediation levels established for soil at the FCX site are based on [0·6 risk for direct
contact with pentachlorophenol, the state-wide background level for pesticides, and EPA's 1 ppb
level for dioxin typically considered to be in the acceptable range of risks. Proper construction
and continued maintenance of the paving would preclude exposure to the soils.
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· INDUSTRIES
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BASE l,IAP SOURCE: EPA SITE MM' DH1El3'4J
G:: i---------------------------------,-------------,,•□°"Y:;--;F~. -,v"'E"'s"'r"□N:-;,-I""N"'c-. ------------!
FCX-STATESVILLE
STATESVILLE, NORTH CAROLINA
~
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u SOIL SAMPLE LOCATIONS
Vl EXCEEDING REMEDIATION LEVELS DRA'.IN v. □. N□.
f-..'. D.O. 04400-01-02
.......J CHECKED ATE APPROVED ATE D\JG. NO.
CL .__ __________ FI_G_U_RE_6_-_1 __________ .J_ _____ .L,__ __ __L._ _____ ..L.,_ __ -1...~0~4:24~0~00~0,;_:4!...J
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 6-1
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Samples Exceeding Cleanup Goals and Estimated Contaminated Soil Volumes
Sample Depth of Contaminant Assumed Assumed Volume
Location Sample (ft) (concentration in mg/kg) Depth (ft.) areal extent (Cubic Yards)
FS-107 0"-6" Pesticides (1.35) PCP (3.5) 1.0 so· x so· 92.6
FS-204 0"-6" Pesticides (8. 77) 1.0 50' X 50' 92.6
FS-205 0"-6" Pesticides (6.28)
24"-36" Pesticides (10.42) 3.0 SO' X SO' 277.8
FS-210 0"-12" Pesticides (3.63) 1.0 50' X SO' 92.6
FS-224 0"-12" Pesticides (3.76) 1.0 50' X 50' 92.6
FS-225 0"-6" Pesticides (10.42) 1.0 SO' X SO' 92.6
FS-226 0"-12" Pesticides (36.30)
24"-36" Pesticides (135.60) 3.0 50' X SO' 277.8
FS-228 0"-6" Pesticides (9.18) 1.0 50' X 50' 92.6
FS-262 48"-60" PCP (I I.OJ 6.0 SO' X 50' 555.6
FS-302 42"-48" Pesticides (172.0)
72"-78" Pesticides (2.09) 10.0 50' X 50' 926.0
FS-306 0"-42" Pesticides (7 .2) 6.0 50' X SO' 555.6
FS-307 0"-72" Pesticides (24.81) PCP (270.0) 6.0 SO' X SO' 555.6
FS-311 0"-6" Pesticides (3 .3) 1.0 50' X SO' 92.6
FS-312 6"-12" Pesticides (116.8) PCP (82.0)
24"-36" Pesticides (2.17) PCP (/.6) 3.0 50' X SO' 277.8
FS-317 0"-6" Pesticides (196.0) PCP (17.0)
108"-114" Pesticides (2.3) 10.0 50' X 50' 926.0
FS-3 I 8 0"-6" Pesticides (49.0)
12"-18" Pesticides (57 .0) PCP (12.0)
38"-42" PCP (11,000) 6.0 SO' X SO' 555.6
FS-319 0"-6" Pesticides (184.0) PCP(l5.0)
12"-16" Pesticides (830.0) PCP (420.0) 3.0 SO' X 50' 277.8
FS-324 60'-72" Pesticides (11.88) 6.0 SO' X SO' 555.6
FS-325 0"-12" Pesticides (3. I)
l2"-18" Pesticides (9.02)
24"-36" Pesticides (5.5) 3.0 SO' X 50' 277.8
FS-326 24"-30" Pesticides (3.8) 3.0 SO' X 50' 277.8
TOTAL 6,945
Samples listed contain concentrations exceeding I mg/kg for total pesticides, 3 .2 mg/kg for PCP, and I µg/kg for dioxin.
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ESTIMATED AREAL tX'TE.NT Of
REQUIRED REMEDIATION.
TOTAL AREA: 17318 SQ. n.
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G::i----------------------------,-~----=--------=c--;c-~=-,-----c-=----------J
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FCX-STATESVILLE
STATESVILLE, NORTH CAROLINA
APPROXIMATE AREAS TO BE CAPPED (ALT. 2)
BASED ON REMEDIATION LEVELS
FIGURE 6-2
DRA\JN
CHECKED
D.O.
APPROVED ATE
'J. □. NO.
04400-11-21
D\JG, NO.
04400003
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
6.4.3 Short-Term Effectiveness
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
During implementation of this alternative, a temporary increase in dust production may occur
during paving activities. The generation of dust can be controlled with water sprays. The
_contaminated soils would essentially remain undisturbed except for those at the extreme surface.
Only OSHA-trained personnel will be allowed to perform general site preparation activities.
Paving contractors would not become involved with contaminated materials and would not be
required to have the OSHA training requirements. Under other OSHA regulations however,
these personnel would be advised of the situation and potential contaminants. Regular safety
meetings with these personnel would be conducted by an experienced hazardous materials
remediation supervisor.
6.4.4 Long-Term Effectiveness and Permanence
The risk of direct contact and leaching of contaminants is eliminated as long as the paved areas
are maintained. Institutional controls used to prohibit excavation at the site are required to
ensure long-term effectiveness.
Because this alternative would leave hazardous substances on-site, a review would be conducted
every five years to ensure that the remedy provide adequate protection of human health and the
environment in accordance with CERCLA 121(c).
6.4.5 Overall Protection of Human Health and the Environment
The asphalt cap and institutional controls would reduce the direct contact risk and soil ingestion
risk to less than I X Io·'. The cap would also mitigate leaching of contaminants to the
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
groundwater by limiting infiltration. Future use of the site would be restricted (by the deed) to
those uses that would not involve removal of the buildings and cap.
After soils are capped along the railroad tracks under this alternative (i.e., at sample locations
-FS-224, FS-225, FS-226, and FS-228), the residual risk would be less than 1 x 10·6• However,
limited groundwater infiltration will continue, since the cap would be discontinuous along the
rails to allow for future use of the rail system.
6.4.6 Reduction of Toxicity. Mobility, or Volume of Contaminants
This alternative does not satisfy the statutory preference for treatment. It provides no reduction
in the toxicity, mobility, or volume of the contaminated soil through treatment.
6.4. 7 Implementability
This alternative can be readily implemented with conventional highway and road pavmg
equipment.
6.4.8 Cost
The capital cost for this alternative has been estimated at $140,000 as presented in Table 6-2.
O&M costs are estimated at approximately $2,500 per year to cover asphalt inspection and
maintenance. The total estimated present worth cost is $255,640.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 6-2
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
FCX -Statesville Feasibility Study Cost Estimate
Alternative 2 -Capping with Deed Restrictions
PROJECT PLANS
MOBILIZATION/DEMOB I
FENCE(LIN. FT.) 500
WAREHOUSE DECON
PAVING
PA YING (SQ YD) 2,000
DEED AMENDMENT I
0 & M COSTS
MONITORING
FENCE AND
PATCHWORK
SUBTOTAL CAPITAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
SUBTOTAL -O&M
ANNUAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY (%)
TOTALi"O&MAN!'{UAL id\iit~YEAR iik\iiEws·
5,000
10,000
15
50,000
6
5,000
25
25
15
25
NOTE: Present worth computation uses a discount rate of 5 % .
5,000
10,000
7,500
50,000
12,000
5,000
2,500
89,500
22,375
27,969
2,500
375
719
30 YEARS
···•··•··••~~:~~i•••••· ·•···x~~t!•~·•~•••ii~0;~wi·•••t•·
This rate is used to transform the future O&M and five-year review costs into equivalent dollars now.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.5 ALTERNATIVE 3 -BUILDING DEMOLITION WITH CAPPING
6.5.1 Description of Alternative
-Alternative 3 is similar to Alternative 2, with the exception that the building will be demolished,
and a cap will be placed over the contaminated soils beneath it. Figure 6-3 shows the areal
extent which would be capped. The demolition of the warehouse building, as shown in Figure
6-3, includes decontamination and razing of the building and disposal of the materials in a
licensed disposal facility. The demolition debris would be disposed in a non-hazardous landfill.
The placement of the cap will be limited to cover the contaminated areas in Areas 2 and 3, and
the small portion in Area 1 south of West Front Street. The cap of the soils along the railroad
tracks will be placed over the existing tracks with gaps to allow for potential future use of the
rail system. The estimated areal extent for the cap placement is 51,500 sq. ft.
6.5.2 Compliance with ARARs
No chemical-specific ARARs have been directly established for the contaminant levels in soils.
The remediation levels established for remedial actions at the FCX site are those relating, in
part, to risk assessment exposure scenarios for pentachlorophenol (PCP). The NCDEHNR
estimates that state-wide background levels of pesticides in soil approximate one part per million
(ppm). EPA-Region IV has established the remediation level for total pesticides in the soil at
one ppm. EPA also established the 1 ppb remediation level for dioxin based on a typical
acceptable risk range of 10"" to 10·'.
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FCX-STATESVILLE
STATESVILLE, NORTH CAROLINA
APPROXIMATE EXCAVATION AREAS
BASED ON REMEDIATION LEVELS
FIGURE 6-3
DRA'w'N
D.O.
CHECKED
DATE DES. ENG.
4-19-94
ATE APPROVED ATE
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D\JG. NO.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
6.5.3 Short-Term Effectiveness
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
During implementa!iO.J!.~QLthis alternative, a temporary increase in dust production may occur
during demolition and pavement installation. The generation of dust can be controlled with
_ water sprays. The contaminated soils would essentially remain undisturbed except for those soils
at the extreme surface.
Potential risks to workers may exist during the decontamination and demolition activities. These
risks are primarily associated with the physical hazards intrinsic to these activities. Air emission
monitoring and worker personnel protection equipment (PPE) provisions would be required to
mitigate against potential exposure hazards, along with adherence to standard OSHA safe
constmction guidelines (e.g., use of hazard tape to restrict area).
6.5.4 Long-Term Effectiveness and Permanence
The risk of direct contact and leaching of contaminants is eliminated as long as the paved areas
are maintained. Demolition and removal of the building will further reduce the risk of direct
contact with any residual contaminants within the building. Institutional controls used to prohibit
excavation at the site is required to ensure long-term effectiveness.
Because the alternative would leave hazardous substances on-site, five-year reviews would be
conducted for 30 years to determine the effectiveness of the remedy toward protection of human
health and the environment and that controls remain in place. These reviews would be required
at least every five years or until contaminant levels allow for unlimited use or unrestricted
exposure. This is a statutory requirement consistent with CERCLA Section 121(c).
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.5.5 Overall Protection of Human Health and the Environment
The asphalt cap would reduce the direct contact risk and soil ingestion risk to less than I x 10-•.
Additional engineering controls by removing the buildings would provide additional protection
_against. the direct contact risk. The cap would also mitigate leaching of contaminants to the
groundwater by limiting surface water infiltration. Future use of the site would be restricted (by
the deed) to those uses not involving removal of the cap.
6.5.6 Reduction of Toxicity. Mobility. or Volume of Contaminants
The alternative does not satisfy the statutory preference for treatment. It provides no reduction
in the toxicity, mobility, or volume of the contaminated soil through treatment. Demolition and
removal of the building will reduce the volume of residual contaminants within the building
structure.
6.5. 7 Implementability
The capping portion of the alternative can be readily implemented with conventional highway
and road paving equipment. Decontamination and demolition equipment would be required to
raze the warehouse building, which are available from several vendors.
6.5.8 Cost
The capital cost for this alternative has been estimated at $1,179,000 as presented in Table 6-3.
O&M costs are estimated at approximately $5,000 per year to cover asphalt inspection and
maintenance. The total estimated present worth is $1,345,640.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Table 6-3
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
FCS-Statesville Feasibility Study Cost Estimate
Alternative 3 -Building Demolition with Capping
PROJECT PLANS
EROSION CONTROL (UN. FT.)
MOBILIZATION/DEMOB
FENCE(LIN. FT.)
WAREHOUSE DEMOLITION
PAVING
PAVING (SQ YD)
DEED AMENDMENT
0 & M COSTS
MONITORING
FENCE AND PATCHWORK
SUBTOTAL CAPITAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
TOT AL -CAPITAL
SUBTOTAL -O&M ANNUAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
··ToTAI.: /O&M ANNUAL· . F'IvE\'EAR Rivrnws
1,000
500
5,700
I
5,000
3
50,000
15
650,000
6
5,000
25
25
15
25
NOTE: Present worth computation uses a discount rate of 5%.
5,000
3,000
50,000
7,500
650,000
34,200
5,000
5,000
754,700
188,675
235,844
1,179,219
INCLUDES DECON AND
DISPOSAL
5,000 30 YEARS
750
1,438 ·.··•<~t~~' 1·f~t:~Jf~J~;JW~••.
This rate is used to transform the future O&M and five-year review costs into equivalent dollars now.
G:\HOME\WP\04400\0t 1\FSSEC6.WP 6-22
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.6 ALTERNATIVE 4 -SOIL EXCAVATION AND THERMAL DESORPTION
WITH BCD
6.6.1 Description
The initial activity required for this alternative is the decontamination, demolition, and disposal
of the warehouse buildings. Portions of the railroad tracks will also be removed to expose
specific areas for excavation. Soils exceeding the cleanup goals would then be excavated and
started for treatment on-site. See Figure 6-3 for approximate areal extent of remediation areas.
The depth of excavation varies from location to location as shown in Table 6-1. General site
preparation activities will include the following:
•
•
•
•
•
Survey and mark the limits of the area to be excavated .
Perform sampling within the buildings to determine the need for decontamination .
Decontaminate the buildings with high pressure wash.
Demolish the warehouse and removal of the railroad tracks to expose identified
remediation areas.
Prepare an area for decontamination of demolition and excavation equipment.
Construct a concrete pad with• curbs and sump for the collection of
decontamination water. The wastewater would be stored and tested to detern1ine
final disposition.
Clean all other areas requiring excavation as required .
Excavation will be performed with standard construction equipment consisting mainly of an
excavator. Some specialized equipment would be required to raze the warehouse buildings and
remove sections of the railroad tracks. Excavated materials would be placed on a lined staging
area prior to treatment. Dust suppression by wetting the·soil would be performed as necessary.
G:\HOME\ WP\04400\011 \FSSEC6.WP 6-23
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express. written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
In addition to the excavation for the identified remediation area, investigation trenches will be
excavated in the eastern half of the upper warehouse area in an attempt to locate alleged 1966
burial of pesticides in trenches. Exploratory borings through the building failed to locate these
alleged trenches. The trenches were reportedly covered with 6 feet of soil. The already
proposed remediation area will encompass most of the area but not to a depth of 6 feet.
Therefore, trenches to at least 6 feet will be excavated in the approximate location shown in
Figure 6-4 following initial soil excavation.
All equipment will be decontaminated prior to demobilization. The approximate quantity of
known contaminated soil is 6,945 cubic yards; the detection of deeper contamination from
verification sampling or trench investigations would increase the volume.
Thermal treatment will be accomplished with a thermal desorption unit such as the Therm-O-
Detox system commercially available from ETG Environmental. For treatment of the
contamination at FCXS, a dechlorination process would be combined with the thermal unit that
operates at temperatures exceeding the boiling points of the contaminants of concern. The
temperatures required will be determined in a bench scale study. Figure 6-5 shows a typical
process schematic of this treatment system. Initially, an inorganic dechlorination reagent is
mixed with the soil prior to heating in the thermal unit, causing some of the chlorinated
contamination to decompose. Contaminants driven off by the thermal unit are condensed and
recovered by scrubbers and condensers. The organic contaminants from the vapor condensate
are treated in a base catalyzed decomposition (BCD) reactor. Separated water can be treated by
liquid phase carbon adsorption and recycled back to the process for use in the scrubbers and
cooling conveyor. Off-gases exiting the vapor recovery system are discharged to the atmosphere
after carbon adsorption polishing.· The BCD process results in complete dehalogenation whereby
all halogen ions are replaced by hydrogen radicals. Oily residues remaining in the BCD reactor
are combustible and can be burned in an oil-fired power plant, a cement kiln, or treated and
G:\HOME\vVP\04400\011\FSSEC6.W'P 6-24
0 z
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• 306
□
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0
SCALE
8
SOIL SAMPLE LOCATION
EXCEEDING Cl..£ANUP l..£\IEL
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'1<1.tJ. ..•.••... XJ?•. "'1-c ...... . ' .. ' tJ ~v~s
RESIDENTIAL
AREA APPROXIMATE AREA ENCOMPASSING
Al...l..EGED PESTIODE BURIAL
APPROXIMATE LOCATlON OF
PROPOSED INVESTIGATION TRENCHES.
150 300
FEET
BURLINGTON
INDUSTRIES
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BASE MAP SOURCE: EPA SITE MAP DH1E134J
G:: r-----------------------------.--------------,~~~=~~--------_j
II
FCX-STA TESVILLE
STATESVILLE, NORTH CAROLINA
PROPOSED LOCATION OF u (/) INVESTIGATION TRENCHES DRA'JN DATE DES. ENG. DATE ',/,□.NO.
i----: D.O. 4~19-94 04400-11-21
-' FIGURE 6-4 CHECKED ATE APPROVED ATE D\IG. NO.
o... '---------------------------'-------'----i__ _____ i__ __ __j__Oo'.4::::4~0"-'0:'.oO!.-"Oc!.1_j
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Figure 6-5
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: ·e
Revision: 1
Date: June 1994
Typical Process Schematic of Thermal Desorption with BCD
COITTAMIW..TED MAITJW,LS
OR SCREENED SOILS r--------------------------------, I VAPOR RECOVERY SYS1EM TO I
I ATMOSPHERE I
I I I WATER I
mo HOPPER
VAPOR DISCHARGES I SCRUBBERS ~<I--< I ~------'-'-'---t---l-I
DECHLORINATION REAGENTS
C, /"',
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FEED CONVEYOR L----------____________________ J
\_/ \.7
BCD SOLIDS R~CTOR
MEDIUM TEMPERATURE THERMAL DESORPTION
(MTTD)
WATER
SPRAY
COOLING WATER C\VC\V
-----,C_O~O~L71N~G~S~CR~FYI"---,->
CONVEYOR
AQUEOUS
CONDENSATE
STORAGE
CARBON
ADSORPTION
ON-SITE BACKFJLL
OR --------<
OFF-SITE DISPOSAL
G:\HOME\WP\04400\011\FSSECS.WP
DECONTAMINATED SOLIDS
CONTAINER
6-26
OILY
CONOENSATE
STORAGE
OIL
DECHLORINATION
REAGENTS
ADOITM:: --ic~i-::----L::::=:,J
TREATED
WATER
BCD
UQUlO
REACTOR (LTR)
RECYL£0 ON-SITE TREATED
OIL/HC
REC'lt..£0 OFF-SITE
==-= L5 {J '0:!::I l!NVIRONllKNTll. INC.
THE BCD TECHNOLOGY AND THE THERM-O-DETOX™ SYSTEM
Rov. f 4,5 Drown By: M. Brockor Doto: 3 15 94
Dwg. #
4010
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
reclaimed by waste oil recyclers. The aqueous condensate is filtered and polished by carbon
adsorption units for use in the process scrubbers. Treated soils will be placed back into the
excavation areas. The backfill will be placed in the excavation and compacted in 12-inch lifts
to approximately 95 percent standard proctor density. On completion of the backfill operations,
-the area will be graded to match the contour of adjacent undisturbed land. Areas disturbed by
excavation will be revegetated or covered with crushed stone as appropriate.
6.6.2 Compliance with ARARs
No chemical-specific ARARs have been directly established for the contaminant levels in soil.
The remediation levels established for soil at the FCXS site are based on 10·• risk for direct
contact with PCP, state-wide background levels for total pesticides, and EPA's I ppb level for
dioxin typically considered in the acceptable range of risks from 104 to 10·•.
Air emissions from the carbon polishing unit of the vapor recovery system would be monitored
to ensure compliance with the State of North Carolina air discharge requirements.
6.6.3 Short-Tenn Effectiveness
During implementation of this alternative, dust created during the excavation must be controlled.
These risks can be addressed during planning and implementation. On-site, the dust can be
controlled with water sprays while an air monitoring plan is implemented to detect any trace
levels of contaminants in the air. This air monitoring program will also detect any contaminants
which may be emitted from the treatment unit. Since the unit uses low speed equipment, noise
levels will be lower than that produced by standard construction machinery.
G:\HOME\v\'P\04400\011\FSSECS.WP 6-27
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Only OSHA trained personnel will be allowed to perform site remedial activities. A site specific
health and safety plan will be developed and implemented which outlines all the physical and
chemical hazards associated with the site. This plan will also present the appropriate personal
protective equipment necessary to safely perform each job function.
Assuming a 10 ton per hour thermal treatment is operating 24 hours per day and including
excavation, the total time to reach remedial response objectives would be approximately 100
working days excluding mobilization/demobilization and inclement weather delays.
6.6.4 Long-Tenn Effectiveness and Pennanence
Contaminated soils will be excavated and treated to remove the contaminants which will
effectively reduce the risk to the public. The removal of the contaminants is permanent and
irreversible. The type of treatment has been effective elsewhere with similar contaminants. A
treatability study will be required at the bench scale level. Since the soil contaminants have been
removed, O&M activities are not necessary.
The soil remediation level of 3.2 ppm for pentachlorophenol will achieve a 10·• risk level based
on the site risk assessment while the 1 ppb level for dioxin achieved a risk level in the range of
104 to 10·• as determined by EPA. The remediation level of 1 ppm for total pesticides is based
on the state-wide background level for pesticides. Remediating the soil to 1 ppm total pesticides
will achieve an estimated 98.4 % reduction in total pesticides. Although the remediation level
of I ppm total pesticides is not based on leachate modeling, EPA believes that achieving the
98.4% reduction in pesticides, in conjunction with the Operable Unit One groundwater pump
and treat system, will achieve adequate protection of human health and the environment. Long-
term groundwater monitoring will also be implemented to ensure protection of human health and
the environment.
G:IHOME\\r\'P\04400\011\FSSEC6,\r\'P 6-28
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesvil!e, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.6.5 Overall Protection of Human Health and the Environment
Over the long-term, this alternative will reduce or eliminate the risk of direct exposure to
contaminants in soil by potential receptors. The contaminated soil will be treated below the
-cleanup levels and therefore would not be a threat for exposure. Pentachlorophenol and dioxin,
the two principal contaminants of concern in the surface soil, would be reduced to the 1()"6 risk
level. The level of total pesticides in the soil would be reduced to I ppm, or an estimated
98.4 % . The contaminants extracted during the desorption process would be collected and
destroyed using the BCD process.
6.6.6 Reduction of Toxicity. Mobility, and Volume
This alternative addresses the principal threats by removmg and treating the source. The
treatment process employs the use of thermal desorption to separate the organic contaminants.
A sigriificant reduction in toxicity, mobility, and volume of contaminated soil is expected.
This treatment leaves organic residue within the vapor-phase carbon units ihat will requ1re
further handling. The carbon can be regenerated for reuse.
Treatment by desorption is an irreversible operation. Treated soils are returned to the
excavation areas. This alternative satisfies the statutory preference for treatment as the principal
element.
G:IHOME\WP\04400\011 \FSSEC6. WP 6-29
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
6.6. 7 Implementability
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
This alternative can be readily implemented with conventional construction and excavation
equipment. Demolition equipment would be required for demolition of the warehouse. The
_excavated soil is treated with commercially available mobile systems which can be transported
to the site.
Thermal desorption treatment systems are commercially available to be mobilized to the site.
Several vendors have thennal systems of this type for which to obtain competitive bids;
however, ETG and SoilTech ATP Systems, Inc. are the only companies at this time which have
licenses for the EPA-patented BCD process.
6.6.8 Cost
The capital cost for this alternative has been estimated at $4,840,000 as presented in Table 6-4
which include warehouse demolition, excavation, treatment, backfilling and land reclamation.
O&M costs would be negligible.
G:\HOME\ WP\04400\011 \FSSEC6.WP 6-30
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Table 6-4
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
FCX-Statesville Feasibility Study Cost Estimate
Alternative 4 -Soil Excavation and Thermal Desorption with BDC
PROJECT PLANS
EROSION CONTROL(LIN.FT.)
MOBILIZATION
WAREHOUSE DEMOLITION
TREATABILITY STUDY
EXCAVATION AND MITD
WITH BCD
EXCAVATION (CY)
MTTD WITH BCD (TONS)
TRANSPORTATION (TONS)
VERIFICATION SAMPLES
BACKFILL (CY)
REGRADE/RESEED(ACRES)
0 & M COSTS
SUBTOTAL CAPITAL
2,000
0
6,945
9,376
0
50
6,945
2
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
40,000
3
0
650,000
40,000
0
250
0
350
0
1,500
25
25
40,000
6,000 SITE PERIMETER (5 ACRES)
0
650,000 INCLUDES DECON AND DISPOSAL
40,000 LAB BENCH SCALE STUDY
0 INCLUDED IN TURNKEY PRICE
2,343,938 JOO PCF (TURNKEY PROJECT PRJCE)
0
17,500 PESTICIDES, PCP, DIOXINS
ANALYSIS
0 INCLUDED IN TURNKEY PRICE
3,000 2 AC
0
3,100,438
775,109
968,887
NOTE: Present worth equals capital costs since there are no future O&M costs for this alternative. Value shown has been
rounded to the nearest $10,000.
G:\HOME\WP\04400\011\FSSEC6.WP 6-31
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6.7 ALTERNATIVE 5 -SOIL EXCAVATION AND THERMAL DESORPTION
6.7.1 Description
-This alternative consists of the excavation of soils (surface and subsurface) that exceed selected
concentration cleanup goals. Soils removed would be treated on-site utilizing thermal desorption
technology. The technology is a physical separation process that volatilizes organic contaminants
from the soil. The resulting vapor-phase organics then exit the system and pass though a
treatment train which includes vapor-phase carbon units to remove residual organics. Recovered
liquids from the vapor phase are collected and sent off-site for incineration. SoilTech ATP
Systems Inc. has demonstrated their system in EPA's Superfund Innovative Technology (SITE)
program and has been successful in treating soils on several Superfund sites. SoilTech's JO-ton
per hour unit can reach temperatures up to I 200°F, is transportable on 26 trailers and is set up
in a 150 feet by 150 feet footprint.
The treated soil will be placed back into the excavation, graded, and compacted to the original
contours prior to remedial actions. The location and extent of remediation areas are the same
as for Alternative 4 and illustrated in Figure 6-3. This figure outlines the areas with
concentrations exceeding cleanup levels. The areal extent of contamination assumes a square
pattern around each location exceeding the cleanup levels and one-half the distance to the next
surrounding "clean" location (approximately 50 ft by 50 ft). The vertical excavation depth is
assumed to be at the maximum depth identified for each specific location. Table 6-1 shows
those sample locations where the cleanup goals are exceeded and the depths where the samples
were obtained. The maximum depth where contamination was found to the nearest I foot, 3
feet, 6 feet, or 10 feet, was used to calculate volumes.
G:\HOM E\WP\04400\011 \FSSEC6, 'NP 6-32
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Prior to excavation and treatment, the following general site preparation is necessary:
•
•
•
•
Survey and mark the limits of the area to be excavated .
Demolish the warehouse in Area 3 to remediate the areas identified beneath the
foundation.
Prepare an area for decontamination of equipment and any warehouse debris .
Construct a concrete pad with curbs and sump for the collection of
decontamination water. The wastewater would be stored and tested to detennine
final disposition.
Clear and grub all other areas requiring excavation .
Excavation will be performed with standard construction equipment consisting mainly of an
excavator. Equipment would be required to raze the warehouse buildings and to remove sections
of the railroad tracks. Excavated materials would be placed on a lined staging area prior to
treatment. Dust suppression by wetting the soil would be performed as necessary. To further
investigate the alleged pesticide burial in 1966, trenches will be excavated to a depth of 6 feet
in the approximate locations shown on Figure 6-4.
The approximate quantity of known contaminated soils is 6,945 cubic yards; the detection of
deeper contamination during verification sampling or trench excavations would increase the
volume. All equipment will be decontaminated prior to moving from the site.
Thermal treatment will be accomplished with a commercially available mobile unit. A treatment
pad area would be required which would include all the necessary utility hook-ups. Pad areas
would also be prepared for staging of pre-treated and treated soils. The State of North Carolina
would be consulted to obtain the necessary air quality permits for stack gases emitted from the
system. The applicable unit would be capable of treating 10 tons per hour.
G:\HOME\ WP\04400\011 \FSSEC6.WP 6-33
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
The treated soils will be placed in the excavation and compacted in 12-inch lifts to approximately
95 percent standard Proctor density. On completion of the backfill operations, the area will be
graded to match the contour of adjacent undisturbed land. Areas disturbed by excavation will
be revegetated or covered with crnshed stone as appropriate. It is assumed that a satisfactory
_borrow source for the top layer will be located within 5 miles of the site.
The site would be monitored following the backfilling to ensure that vegetation remains and that
erosion is prevented.
6.7.2 Compliance with ARARs
No chemical-specific ARARs have been directly established for the contaminant levels in soil.
The remediation levels established for soil at the FCXS site are based on the I o-6 risk for direct
contact with PCP, an EPA accepted 104 to 10-6 risk range for dioxin, and the state-wide
background level for total pesticides.
Air emissions from the vapor recovery systems would be monitored to ensure compliance with
the State of North Carolina air discharge requirements.
6. 7 .3 Short-Tenn Effectiveness
During implementation of this alternative, potential risks involve dust created during the
excavation. These risks can be addressed during planning and implementation. On-site, the dust
can be controlled with water sprays while an air monitoring plan is implemented to detect
contaminants which may be emitted from the treatment unit. Since the unit uses low speed
equipment, noise levels will be lower than that produced by standard constrnction machinery.
G:\HOME\WP\04400\011 \FSSECS.WP 6-34
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Only OSHA trained personnel will be allowed to perform site remedial activities. A site-specific
health and safety plan will be developed and implemented which outlines all the physical and
chemical hazards associated with the site .. This plan will also present the appropriate personal
protective equipment necessary to safely perform each job function.
Assuming a 10 ton per hour thermal treatment is operating 24 hours per day, the total time to
reach remedial response objectives would be approximately 100 working days excluding
mobilization/demobilization and inclement weather delays.
6.7.4 Long-Term Effectiveness and Permanence
Contaminated soils will be excavated and treated to remove the contaminants which will
effectively reduce the risk to the public. The removal of the contaminants is permanent and
irreversible. Although this technology has been proven in full-scale operations on similar
contaminants, a treatability study will be required at the bench scale level. Since soils will be
treated, long-term O&M activities are not necessary.
The soil remediation level of 3.2 ppm for pentachlorophenol will achieve a 10·• risk level based I on the site risk assessment while the I ppb level for dioxin achieved a risk level in the range of
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104 to 10·• as determined by EPA. The remediation level of I ppm for total pesticides is based
on the state-wide background level for pesticides. Remediating the soil to I ppm total pesticides
will achieve an estimated 98.4 % reduction in total pesticides. Although the remediation level
of I ppm total pesticides is not based on leachate modeling, EPA believes that achieving the
98.4 % reduction in pesticides, in conjunction with the Operable Unit One groundwater pump
and treat system, will achieve adequate protection of human health and the environment. Long-
term groundwater monitoring will also be implemented to_ ensure protection of human health and
the environment.
G:\HOME\ WP\04400\011 \FSSEC6.WP 6-35
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
6. 7.5 Overall Protection of Human Health and the Environment
Over the long-term, this alternative will reduce or eliminate the risk of direct exposure to
contaminants in soils by potential receptors. The contaminated soil will be treated below cleanup
Jevels and therefore would not be a threat for exposure. The contaminants extracted during the
desorption process would be collected on activated carbon and sent off-site for incineration.
6.7.6 Reduction of Toxicity. Mobility. and Volume
This type of treatment addresses the principal threats by removing and treating the source. The
treatment process employs the use of thermal desorption to separate the organic contaminants.
A significant reduction in toxicity, mobility, and volume of contaminated soil is expected. This
alternative satisfies the statutory preference for treatment as the principal element.
This treatment leaves condensed liquids from the off-gases and organic residue within the vapor-
phase carbon units that will require further handling. The carbon can be regenerated for reuse.
6. 7. 7 Implementability
This alternative can be readily implemented with conventional construction and excavation
equipment. Demolition equipment may be required for demolition of the warehouse. The
excavated soil is treated with commercially available mobile systems which can be transported
to the site. These mobile units such as the SoilTech ATP are proven and have shown to be
successful on at least three Superfund projects. Several vendors are available from which to
obtain a competitive bid.
G:\HOME\WP\04400\011\FSSECS.WP 6-36
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
6.7.8 Cost
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
The capital cost for this alternative has been estimated at $6,150,000 as presented in Table 6-5,
which includes warehouse demolition, excavation, treatment, backfilling and land reclamation.
-O&M costs would be negligible.
6.8 SOIL ALTERNATIVE 6 -SOIL REMOVAL & OFF-SITE INCINERATION
6.8.1 Description
The initial step of this alternative consists of decontamination, demolition, and disposal of the
warehouse buildings. Portions of the railroad tracks will also be removed to expose specific
areas for excavation. Soils that exceed the cleanup goals would be excavated and staged on-site.
Soils removed would be transported to an off-site permitted incinerator for treatment as a
hazardous waste. For purposes of this study, it is assumed that the soils will be managed as a
RCRA-characteristic hazardous waste. The excavation will be backfilled with clean soil, graded,
and compacted to the original elevations prior to remedial actions. The location and areal extent
of remediation areas is shown on Figure 6-3. The areal extent of contamination assumes a
square pattern around each location exceeding the cleanup levels and one-half the distance to the
next surrounding "clean" location (approximately 50 ft by 50 ft). The vertical depth of
contamination is assumed to be the maximum depth where contamination was observed for each
specific borehole. Refer to Table 6-1 for those sample locations where the cleanup goals are
exceeded including the depths where the samples were obtained. The maximum depth where
contamination was found to the nearest I foot, 3 feet, 6 feet, or 10 feet, was used to calculate
volumes.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Table 6-5
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
FCX-Statesville Feasibility St.udy Cost Estimate
Alternative 5 -Soil Excavation and Thennal Desorption
PROJECT PLANS 1
EROSION CONTROL(LIN.FT.) 2,000
MOBILIZATION/DEMOB
WAREHOUSE DEMOLITION I
TREATABILITY STUDY
EXCAVATION AND THERMAL TREATMENT
EXCAVATION (CY)
HI TEMP TREATMEN(TONS)
TRANSPORTATION (TONS)
VERIFICATION SAMPLES
BACKFIU
BACKFILL (CY)
REGRADE/RESEED(ACRES)
0 & M COSTS
SUBTOTAL CAPITAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
TOTAL -CAPITAL
6,945
9,376
0
50
6,945
2
40,000
3
1,200,000
650,000
40,000
10
200
0
350
5
1,500
25
25
40,000
6,000
1,200,000
650,000
40,000
69,450
1,875,150
0
17,500
34,725
3,000
0
3,935,825
983,956
1,229,945
6,149,727
SITE PERIMETER (5 ACRES)
INCLUDES DECON AND DISPOSAL
LAB BENCH SCALE STUDY
100 PCF
PESTICIDES, PCP, DIOXINS
ANALYSIS
REPLACEMENT OF TREATED SOIL
2 AC
NOTE: Present worth equals capital costs since there are no future O&M costs for this alternative. Value shown has been
rounded to the nearest $10,000.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
Prior to excavation and treatment, the following general site preparation is necessary:
•
•
•
•
Survey and mark the limits of the area to be excavated .
Demolish the warehouse in Area 3 to remediate the areas identified beneath the
foundation.
Prepare an area for decontamination of equipment and any warehouse debris .
Construct a concrete pad with curbs and sump for the collection of
decontamination water. The wastewater would be stored and tested to determine
final disposition.
Clear and grub all other areas requiring excavation .
Excavation will be performed with standard construction equipment consisting mainly of an
excavator. Demolition equipment would be required to raze the warehouse buildings and to
remove sections of the railroad tracks. Excavated materials would be placed on a lined staging
area prior to treatment. Dust suppression by wetting the soil would be performed as necessary.
To further investigate the alleged pesticide burial in 1966, trenches will be excavated to a depth
of 6 feet in the approximate locations shown on Figure 6-4. The estimated soil volume to be
excavated (6,945 cu. yds.) may increase pending the detection of deeper contamination from
verification sampling or trench investigations.
Trucks to transport soil to an approved incineration facility will enter designated areas of the site
and will be directed to a specific loading area. Movement of the trucks will be kept to a
minimum on-site to prevent the spread of contamination off-site. Each truck must adhere to
U.S. Department of Transportation (DOT) requirements for hazardous waste transport including
proper manifesting.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
The nearest approved incinerator is the Thermalkem facility located in Rock Hill, South
Carolina, approximately 100 miles from the FCXS site. The next closest is the LWD facility
located in Calvert City, Kentucky. This facility is approximately 550 miles from the site. For
cost estimating purposes, it is assumed that the LWD facility will be used for disposal since
_costs obtained from the facilities indicated that LWD would offer a lower unit price for
incineration, offsetting the increased transportation costs. Transportation costs are based on
loaded miles which range from $2.50 to $3.50 per mile. Assuming a legal load limit of 22 tons
and $3.00 per mile, the transportation costs are $75.00 per ton. Incineration costs are based
upon tonnage; therefore, it is assumed that the soil density following excavation will be 100
pounds per cubic foot for cost estimating purposes.
Off-site clean soil capable of sustaining vegetation will be used to fill the excavation. It is
assumed that a satisfactory borrow source will be located within 5 miles of the site. The clean
' fill will be placed in the excavation and compacted in 12-inch lifts to approximately 95 percent
standard Proctor density. On completion of the backfill material, the area will be graded to
match the contour of adjacent undisturbed land. All areas disturbed by excavation will be
revegetated or covered with crushed stone as appropriate.
6.8.2 Compliance with ARARs
No chemical-specific ARARs have been directly established for the contaminant levels in soil.
The remediation levels established for soil at the FCXS site are based on 10·6 risk for direct
contact with PCP, state-wide background levels for total pesticides, and EPA's I ppb level for
dioxin typically considered in the acceptable range of risks from 104 to 10·6.
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This document was prepared by Roy F, Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report·
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
It is assumed that the contaminated soil is classified as a hazardous waste. It is also assumed
that RCRA Land Disposal Restrictions apply and that these soils could not be directly landfilled
without treatment.
_Transportation of the material off-site will be performed with licensed bulk dump trncks with
an estimated capacity of 20 cubic yards. RCRA regulations require the generator and transporter
to comply with the manifest system for each shipment of hazardous material transported off-site.
Additionally, the Department of Transportation requires specific placarding for vehicles in
conjunction with the manifesting procedure.
6.8.3 Short-Tenn Effectiveness
During the implementation of this alternative, dust created during the actual excavation, soil
erosion, and trnck traffic through the community will be controlled. All of these potential risks
can be addressed during planning and implementation. On-site, the dust can be controlled with
water sprays while an air monitoring program is implemented to detected any trace levels of
contaminants in the air. Soil erosion can be controlled with silt fences placed in downgradient
areas. To prevent any contamination from being spread by trncks, a decontamination area will
be constrncted and the trncks decontaminated prior to departing the site.
Only OSHA trained personnel will be allowed to perform activities at the site during remedial
activities. A site-specific health and safety plan will be developed and implemented outlining
all the physical and chemical hazards associated with the site. This plan will also present the
appropriate personal protective equipment necessary to safely perform each job function during
the remediation work.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
The total time for building demolition, excavation, and transportation is estimated to be 60
working days excluding mobilization/demobilization and inclement weather days.
6.8.4 Long-Term Effectiveness and Permanence
Contaminated soils will be excavated and permanently removed from the site which would
effectively reduce the risk to the public. The removal of the contaminants is permanent and
irreversible. Since the soil contaminants have been removed, O&M activities are not necessary.
The soil remediation level of 3.2 ppm for pentachlorophenol will achieve a 10·• risk level based
on the site risk assessment while the 1 ppb level for dioxin achieved a risk level in the range of
IO"' to 10·• as determined by EPA. The remediation level of 1 ppm for total pesticides is based
on the state-wide background level for pesticides. Remediating the soil to 1 ppm total pesticides
will achieve an estimated 98.4 % reduction in total pesticides. Although the remediation level
of 1 ppm total pesticides is not based on leachate modeling, EPA believes that achieving the
98.4 % reduction in pesticides, in conjunction with the Operable Unit One groundwater pump
and treat system, will achieve adequate protection of human health and the environment. Long-
term groundwater monitoring will also be implemented to ensure protection of human health and
the environment.
6.8.5 Overall Protection of Human Health and the Environment
Over the long-tenn, this alternative will reduce or eliminate the risk of direct exposure to
contaminants in soils by potential receptors. The contaminated soil will no longer be present
on-site and therefore would not be available for exposure or leaching to groundwater. The soil
contaminants would be destroyed during incineration.
G:\HOME\ WP\04400\011 \FSSEC6.WP 6-42
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
6.8.6 Reduction of Toxicity. Mobility. and Volume
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
This type of treatment addresses the principal threats by removing and treating the source.
The treatment process employs the use of incineration to the destroy organic contaminants.
_A significant reduction in toxicity, mobility, and volume of contaminants is expected.
Treatment by incineration is an irreversible operation and sometimes produces a slag-type
material. This alternative satisfies the statutory preference for treatment as the principal
element.
6.8. 7 Implementability
This alternative can be readily implemented with conventional construction and excavation
equipment. Demolition equipment may be required for demolition of the buildings. The
excavated materials must be accepted at a RCRA approved facility prior to being transported.
Based upon conversations with current incinerator facilities, the contaminants involved at the
FCXS site are treatable and sufficient capacity is available. Transportation will require
permitting and proper manifesting.
6.8.8 Cost
The capital costs associated with this alternative has been estimated at $17,100,000 as presented
in Table 6-6 which includes excavation, transportation, disposal, backfilling and land
reclamation. O&M costs would be negligible.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
Table 6-6
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 6
Revision: 1
Date: June 1994
FCX-Statesville Feasibility Study Cost Estimate
Alternative 5 -Soil Excavation and Off-Site Soil Incineration
EROSION CONTROL(LIN.FT.) 2,000
MOBILIZATION I
WAREHOUSE DEMOLITION I
EXCAVATION AND
INCINERATION
EXCAVATION (CY) 6,945
INCINERATION (TONS) 9,376
TRANSPORTATION (TONS) 9,376
VERIFICATION SAMPLES 50
BACKFIU
BACKFILL(CY) 6,945
REGRADE/RESEED(ACRES) 2
0 & M COSTS
SUBTOTAL CAPITAL
ENGINEERING, ADMINISTRATION(%)
CONTINGENCY(%)
40,000
3
10,000
650,000
10
1,000
75
350
10
1,500
25
25
40,000
6,000
10,000
650,000
69,450
9,375,750
703,181
17,500
69,450
3,000
0
10,944,331
2,736,083
3,420,104
SITE PERIMETER (5 ACRES)
INCLUDES DECON AND DISPOSAL
100 PCF
$3.00/LOADED MILE & 22 TONS/LOAD
MATERIAL, TRANS., & PLACEMENT
2 ACRES
NOTE: Present worth equals capital costs since there are no future O&M costs for this alternative. Value shown has been rounded to the nearest $10,000.
G:\HOME\ WP\04400\011 \FSSECS.WP 6-44
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
SECTION 7
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
COMPARATIVE ANALYSIS OF ALTERNATIVES
In this section, the alternatives described and evaluated in the Section 6 are compared with each
other.
The evaluated alternatives are:
Alternative I:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
Alternative 6:
No Action
Limited Action/Capping
Building Removal/Capping
Excavation, Thermal Desorption with BCD
Excavation, Thermal Desorption
Excavation, Off-Site Incineration
The alternatives are compared to each other with respect to the seven evaluation criteria in the
following subsections.
7.1 EVALUATION CRITERIA COMPARISON
7.1.1 Overall Protection Of Human Health And The Environment
This criterion addresses the overall protecti'veness of the alternative. All of the alternatives meet
the objectives of this criterion to some extent except for _the No Action Alternative which does
NOR/G:\HOME\ WP\04400\011 \FSSEC7.WP 7-1
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
not achieve any remedial goals and risks remain unmitigated. Alternatives 2 and 3 provide
protection from direct contact to contaminated soils and from leaching of contaminants to
groundwater by covering soil with asphalt.
_Soil Alternatives 4, 5 and 6 will remove or reduce the organic contaminants in the soils to below
the remediation goals. These alternatives will also eliminate the source of contamination to
groundwater.
7 .1.2 Compliance with ARARs
While there are no regulatory levels for soil cleanup, the No Action Alternative would not meet
the remediation goals established for site soils. The remediation levels would not apply to the
site after capping under Alternatives 2 and 3. Alternatives 4, 5, and 6 would achieve
remediation levels.
Alternative 6 must adhere to DOT regulations for transportation of hazardous materials if the I soil is determined to be a hazardous waste. Table 7-1 provides a comparative summary of the
compliance of the six alternatives with the ARARs identified in Section 2.
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7 .1.3 Short-Tenn Effectiveness
This criterion involves the protection of the community and on-site workers during
implementation of the remedial alternative as well as the environmental impact from the
alternative implementation. For Alternative I, there is no protection to the community or
mitigation of environmental impacts from existing contamination.
NOR/G:\HOME\INP\04400\011 \FSSEC7. \NP 7-2
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I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Table 7-1
ARARs Compliance Summary
Alternative I Alternative 2 Alternative 3 Alternative 4
Thermal
Limited Action Building Removal/ Desorption with
No Action Capping Capping BCD
Chemical Specific
Remediation levels Cleanup criteria Cleanup criteria Same as Expected to meet.
exceeded. would not apply Alternative 2.
after capping.
RCRA Toxicity NIA NIA NIA Expected to meet
Characteristic
(treated soil)
Action Specific
Land Disposal NIA NIA NIA Expected to meet.
Restrictions ( 40
CFR 268)
Closure with Will not meet. Expected to meet. Expected to meet. NIA
Waste in Place (40
CFR 264.111)
NOA/G;\HOME\ WP\04400\011 \FSSEC7 .WP 7-3
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative 5 Alternative 6
Thermal Off-Site
Desorption Incineration
Expected to meet. Will meet.
Expected to meet. Expected to meet.
.
Expected to meet. Will meet.
NIA NIA
-
-· --,,. --·--'\ ------
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
-Alternative 1
No Action
Solid Waste NIA
Disposal ( 40 CFR
241.200-212)
Air Emission NIA
(ISA NCAC)
NOR/G;\HOME\ WP\04400\011 \FSSEC7 .WP
Table 7-1 (Continued)
ARARs Compliance Summary
Alternative 2 Alternative 3 Alternative 4
Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
NIA NIA NIA
NIA NIA Expected to meet.
7-4
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative 5 Alternative 6
Thermal Off-Site
Desorption Incineration
NIA Non-hazardous
residuals will be
disposed off-site
dependent on
analysis.
Expected to meet. Expected to meet.
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This document was prepared by Roy F, Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part,
without the express written permission of EPA
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section; 7
Revision: 1
Date: May 1994
Alternatives 2 and 3 do not involve excavation, so their short-term effects would be minimal. 1
The short-term effectiveness of Alternatives 4, 5, and 6 is somewhat diminished, since the~1
involve excavation of contaminated soils. However, measures would be taken (such as. dust
r
control and protective clothing for workers) to mitigate the short-term effects.
7.1.4 Long-Term Effectiveness
This criterion involves the adequacy and reliability of the alternative. For Alternative 1, the
r
only way remedial objectives would be met would be through long-term natural degradation,
I
leaching, and dispersion in the groundwater. It is questionable if these objectives could be met
I
in this manner. Alternatives 2 and 3 would be effective in reducing the direct contact ris)cs and
r would continue as long as the asphalt cover is properly maintained. They would also redpce the
amount of infiltration and leaching into the groundwater.
Alternatives 4, 5, and 6 provide permanent and effectiye means in achieving the ,remedial
/ . objectives, since the organic contaminants will be removed and treated. All of these alternatlves
would eliminate direct contact risks and the source for groundwater contamination. '
7.1.5 Reduction Of Toxicity. Mobility. and Volume
This criterion is used to evaluate the effectiveness of the alternative in reducing cdntamination.
i
This criterion evaluates the amount of contaminants treated or destroyed, the degre,e of reduction
of toxicity, mobility, and volume, the degree of irreversibility, and the type a'nd amount of
' residuals remaining. For Alternative I there is no reduction of contaminant tax/city, mobility,
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This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in wholEl or in part,
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: May 1994
and volume as there is no active remediation of the soils. For Alternatives 2 and 3, contaminant
mobility is reduced by preventing infiltration through contaminated soil.
For Alternatives 4 and 5 the organic contaminants are desorbed from the soil to reduce their
concentration to below the soil remediation levels. For these alternatives, the organic vapors
driven off the soils are condensed, collected, and destroyed in the BCD reaction or collected on
activated carbon and sent off-site for incineration.
For Alternative 6, the contaminants are destroyed. The incineration process 1s completely
irreversible.
7.1.6 Implementability
This criterion involves the ability to construct the technology, the ease of site preparation, ability
to monitor effectiveness and to undertake additional measures if necessary, obtaining regulatory
approval, and availability of materials and special services. For Alternative I, No Action, the
implementability criteria is not applicable. Alternatives 2 and 3 would require covering the
contaminated areas. This is easily performed with standard road paving equipment. Additional
demolition equipment will be required for removal of the warehouse buildings under
Alternative 3.
Alternatives 4 and 5 have similar components requiring the setup of mobile treatment systems.
Both of these systems are available to handle the volume of contaminated soils at the site. On-
site thermal treatment may encounter some community resistance, however.
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This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part.
without the express written permission of EPA.
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: May 1994
Alternative 6 reqmres off-site transport to a permitted incinerator. Permitted facilities are
available to handle the volumes at the site. The state may object to sending the materials out
of state for treatment.
_ Alternatives 4, 5, and 6 are similar in that site preparation would require demolition of the
warehouse to remediate contaminated soils beneath the building: While this is not a complicated '
effort, it does require special attention. For all three alternatives, confirmation soil sampling
would be performed to monitor the effectiveness of the treatment.
7.1.7 Costs
No capital costs are associated with Alternative 1, the No Action Alternative; however, five-year
reviews at $20,000 per review would be included. The estimated cost for limited action
Alternative 2 is $255,640. Among the alternatives that achieve additional protection of human
health and the environment, Alternative 4 (Thermal Desorption with BCD) has the lowest cost
at $4,840,000. It should be noted that the cost differential between Alternatives 4 and 5 is not
a reflection of the costs associated with the treatment of the condensed off-gas. The cost for
implementing the BCD process with thermal desorption is nearly the same as sending recovered
liquids off-site for incineration. The significant cost difference between Alternatives 4 and 5 is
a result of estimated prices from different vendors at the time they were surveyed.
7.1.8 Summary
A summary of the comparative analysis of soil alternatives is presented in Table 7-2.
NOR/G:\HOME\W'P\04400\011 \FSSEC7 .WP 7-7
----
Th!s document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Alternative 1
Criteria
No Action
Overall Protection of Does not mitigate
Human Health and the risks or achieve
Environment remediation goals.
Compliance with ARARs
• Chemical-Specific Does not meet.
(Cleanup Goals}
• Action-Specific NIA
• Location-Specific NIA
• Compliance with Does not meet
Other Criteria, CERCLA
Waiver Laws and preference for
Guidance treatment remedies.
G:\HOME\W'P\04400\011\FSSEC7.WP
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Table 7-2
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4
Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
Would limit direct Higher degree of Eliminates the risk of
exposure and protection against exposure to soil
protect human exposure than contaminants by
health. Meets Alternative 2. Meets human receptors.
criterion. criterion. Exceeds criterion.
NIA NIA Expected to meet.
NIA NIA Treated soil must
meet LD R treatment
levels if hazardous.
NIA NIA NIA
Does not meet Does not meet Meets CERCLA
CERCLA CERCLA preference Guidance.
preference for for treatment
treatment remedies. remedies.
7-8
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative 5 Alternative 6
Thermal Desorption Off-Site Incineration
Same as Alternative Same as Alternative 4.
4.
Expected to meet. Expected to meet.
Treated soil must Must meet RCRA
meet LD R treatment LDRs and DOT
levels if hazardous. manifesting proce-
dures if hazardous.
NIA NIA
Meets CERCLA Meets CERCLA
Guidance. Guidance.
----.. -- -... -This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Alternative 1
Criteria
No Action
Short-Term Effectiveness
• • Protection of NIA
Community During
Implementation
• Protection of NIA
Workers
• Environmental NIA
Impact
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Table 7-2 (Continued)
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4
Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
NIA Dust control Controls required to
measures would be protect against dust
required during generation during
building demolition. excavation and
building demolition.
No significant risk Physical hazards Protection required
to workers. associated with against dermal
building demolition. contact and inhalation
of contaminated dust
during excavation,
demolition, and
treatment.
Minimal Minimal Minimal
7-9
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative S Alternative 6
Thermal Desorption Off-Site Incineration
Controls required to Controls required to
protect against dust protect against dust
generation during generation from
excavation and excavation, building
building demolition. demolition, and truck
traffic.
Protection required Protection required
against dermal against dermal
contact and inhalation contact and inhalation
of contaminated dust of contaminated dust
during excavation, during excavation,
demolition, and demolition, and
treatment. trucking.
Minimal Minimal
-------@II --
This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
Alternative 1
Criteria
No Action
Long-Term Questionable
Effectiveness whether soil
remediation goals
can be met through
natural degradation.
Five-year review
required.
Reduction of Toxicity, Mobility, and Volume
• Treatment Process None
Used and Materials
Treated
• Amount of None
Hazardous
Materials
Destroyed or
Treated
G:\HOME\ WP\04400\011 \FSSEC7.WP
j
Table 7-2 (Continued)
Evaluation of Remedial Alternatives
Alternative 2 Alternative 3 Alternative 4
Thermal
Limited Action Building Removal/ Desorption with
Capping Capping BCD
Reduces continued Same as Alternative Provides permanent
infiltration and 2. and effective means
leaching of of eliminating source
contaminants into for groundwater
groundwater. contamination.
Eliminates direct
contact risks. Five-
year review
required.
None None Achieves treatment.
None None 6,945 cubic yards of
contaminated soil
treated.
7-10
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative S Alternative 6
Thermal Desorption Off-Site Incineration
Same as Alternative Same as Alternative 4.
4.
Achieves treatment. Achieves treatment.
6,945 cubic yards of 6,945 cubic yards of
contaminated soil contaminated soil
treated. destroyed.
-_,_ -
This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
j
Table 7-2 (Continued)
Evaluation of Remedial Alternatives
Alternative 1 Alternative 2 Alternative 3 Alternative 4
Criteria Thennal
Limited Action Building Removal/ Desorption with
No Action Capping Capping BCD
• Degree of expected None None None Reduction of soil
reduction in contamination below
toxicity, mobility, soil remediation
and volume. goals.
• Degree of NIA Cap and buildings Cap could be Process would be
Irreversibility could be removed. removed. irreversible.
• Type and quantity NIA NIA NIA Residual soil
of residuals contamination below
remaining. remediation levels
and backfilled.
Implementability
• Ability to NIA Road paving Road paving Mobile units
Construct and equipment easily equipment operated commercially
Operate the operated. easily. Building available to handle
Technology. demolition requires the expected soil
additional planning volumes. Demolition
but easily performed. and excavation
implementable.
G:\HOME\ WP\04400\011 \FSSEC7 .WP 7-11
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative 5 Alternative 6
Thermal Desorption Off-Site Incineration
Reduction of soil Greater than 99.99%
contamination below destruction of organic
soil remediation contaminants through
·goals. incineration.
Process would be Process would be
irreversible. irreversible.
Same as Alternative Ash residual disposed
4. of by incineration
facility.
Mobile units are Permitted incinerators
available to handle are available with the
the expected soil capacity to handle the
volumes. Demolition expected soil volumes.
and excavation Demolition and
implementable. excavation
implementable.
... -------------This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA.
I
Table 7-2 (Continued)
Evaluation of Remedial Alternatives
Alternative 1 Alternative 2 Alternative 3 Alternative 4
Criteria Thermal
Limited Action Building Removal/ Desorption with
No Action Capping Capping BCD
• Ease of Site NIA Only minor grading Would require Would require
Preparation required. decontamination and warehouse demolition
demolition of and decontamination
buildings. facilities.
• Ease of NIA Would not interfere Would not interfere Would not interfere
Undertaking with any future with any future with any future
Additional actions. actions. actions.
Remedial Actions
• Ability to Monitor NIA Pavement would be Same as Alternative Confirmation soil
Effectiveness inspected for 2. sampling easily
cracks. performed.
• Ability to Obtain NIA NIA NIA Community may
Approval from express concern over
Other Agencies thermal treatment on-
site.
• Availability of NIA All materials All materials All materials obtained
Materials obtained easily. obtained easily. easily.
• Availability of NIA None needed. Building demolition Building demolition
Unusual or Special equipment obtained equipment obtained
Services easily. easily.
G:\HOME\ WP\04400\011 \FSSEC7.WP 7-12
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative S Alternative 6
Thermal Desorption Off-Site Incineration
Same as Alternative Same as Alternative 4 .
4.
Would not interfere Would not interfere
with any future with any future
actions. actions.
Same as Alternative Same as Alternative 4 .
4.
Same as Alternative State may object to
3. sending materials out
of state.
All materials obtained All materials obtained
easily. easily.
Building demolition Building demolition
equipment obtained equipment obtained
easily. easily.
------ -------This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA
j
Table 7-2 (Continued)
Evaluation of Remedial Alternatives
Alternative l Alternative 2 Alternative 3 Alternative 4
Criteria Thermal
Limited Action Building Removal/ Desorption with
No Action Capping Capping BCD
Estimated Cost (I 994 $)
• Capital Cost 0 $139,844 $1,084,881 $4,840,000
• Annual O&M Cost $ 4,000 $ 8,000 $ 0
(Years 1-30) $ 20,000 * $ 20,000 * $ 20,000 *
• Prysent Worth ** $ 55,640 $255,640 $1,345,640 $4,840,000
* Review performed every 5 years.
** Present worth calculated using a discount rate of 5 % and 30-year -life where O&M costs are included.
G:\HOME\WP\04400\011\FSSEC7.WP 7-13
Feasibility Study Report
FCXS OU2, Statesville, North Carolina
Section: 7
Revision: 1
Date: June 1994
Alternative 5 Alternative 6
Thermal Desorption Off-Site Incineration
$6,150,000 $ I 7,100,000
$ 0 $ 0
$6,150,000 $17,100,000