NCD003188844_19890305_Carolina Transformer_FRBCERCLA RI_Remedial Investigation Feasability Study Work Plan-OCR

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
·4wo-SFB
MAR O & 1989 Ms. Charlotte Varlashkin
3•5 COURTLAND STREET
ATLANTA, GEORGIA 30315
NC Department of Natural Resources
P.O. Box 2091
Raleigh, NC 27602
RE: Carolina Transformer Site
Fayetteville, North Carolina
Dear Ms. Varlashkin:
Please find enclosed a copy of the draft RI/FS Work Plan for the subject
site. The EPA will be conducting this RI/FS as an "in-house" project,
therefore State participation is vital to a high-quality, expeditious RI/FS.
I am requesting you review this Work Plan and provide me with comments no
later than Wednesday, March 22, 1989.
If you have any questions or feel you will be unable to return comments by
March 22, please call me at 404/347-7791.
Sincerely,
M;t)Jt /Jf.~
Michelle M. Glenn
Remedial Project Manager
Enclosure
cc: Lee Crosby, NCDNR (letter only)
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WORK PLAN
FOR
CAROLINA TRANSFORMER SITE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
FAYETTEVILLE, NORTH CAROLINA
JANUARY 1989
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Concurrence of the Carolina Transformer Company Work Plan
to Govern the Remedial Investigation/Feasibility Study
in Fayetteville, Cumberland County, North Carolina
Prepared and
Approved By:
Approved By:
Approved By:
Approved By:
Approved By:
Approved By:
Approved By:
Jon K. Bornholm
Superfund Project Manager
Jon Johnston
North Carolina/South Carolina
Unit Chief
Richard D. Green
North Site Management
Section Chief
Richard D. Stonebraker
Superfund Branch Chief
Patrick Tobin
Waste Management Director
Doug Lair
Hazardous Waste Section Chief
Wade Knight
Quality Assurance & Laboratory
Evaluation Section Chief
Date:
Date:
Date:
Date:
Date:
Date:
Date:
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TABLE OF CONTENTS
Section Page
1.0 EXECUTIVE SUMMARY ............................................. 1-1
2. 0 INTRODUCTION ••••••••••..••......••.•.........•••............•• 2-1
2 .1 Site Location and History ..••••••••...••••...•••••••••••• 2-1
2. 2 Site Status and Project Type ...••...•.••..••••........... 2-5
2. 3 Overview ••••.•••••••••••.••.....••••••...•••••.....•••••• 2-6
3. 0 INITIAL SITE EVALUATION • • . • • • • • • . • • . • . • • • • • • • • • • • • • • • • • • • • . . . . 3-1
3 .1 Site Description •••••••••••••••....••••••••.••••.••••.••• 3-1
3. 1. 1 Environmental Setting ......•.••••.•.••••••••••.•.• 3-1
3.1.1.1 Geology ••••...••••••••••..•.••••••.•..•.. 3-1
3. 1. 1. 2 Hydrogeology • • • • . . . • . • • • • • . . . • • • • • • • • • • . . 3-3
3. 1. 1. 3 Climate . • • • • • • • • • • • • • • . • • • • • • • • • • . . • . • • • • 3-3
3.1.2 Review of Existing Data Base ...................... 3-3
3. l. 2. l Groundwater . • • • • • • • • • • • • . • • • • • • • • • • • • • • . . 3-3
3."1.2.2 Surface Water/Sediment ••••••••••••.•...•• 3-7
3.1.2.3 Soil •••••••••.•.•••••••••••..••••.••••••• 3-14
3.2 Contamination Problem Definition .....••••.•••••••••.•.••• 3-14
3. 2. l Waste Disposed of Onsite • • • • • • • • • • • • • • • • • • • • . • . • • • 3-14
3. 2. 2 Toxicity of Contaminants •••••••••.•••••••••••••••• 3-14
3.2.3 Degree of Site Contamination ••..•••••••••••••••••• 3-21
3.3 Contaminant Migration and Environmental Health Effects •.• 3-21
3.3.l
3.3.2
3.3.3
3.3.4
3.3.5
3.3.6
Migration Pathways 3-22
3.3.1.1 Constituent Pathway and Transport
Evaluation ••..•.••••.••.••••••••••••••••• 3-22
3.3.1.2
3.3.1.3
Unsaturated Zone . • • • • • • • • • • • • • • • • • • • • • • • • 3-22
Groundwater •••••••••••••••.•••••.•..•..•. 3-22
3.3.1.4 Surface Water/Sediment ••••••••••••••••••• 3-23
3.3.1.5 Air .•••••••••••••••••••••••••••••.••••..• 3-23
Public Health and Environmental Assessment •.•..•. 3-24
Health Assessment ••••••••••••••••••••••••••••••••• 3-24
Potential Receptors ••.•.••.•..•••..•.•••••.•.•..•. 3-24
Environmental and Public Health Effects .•.•.•••••• 3-25
References 3-26
4.0 PRELIMINARY ASSESSMENT OF REMEDIAL ALTERNATIVES•••••••••••••·· 4-1
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TABLE OF CONTENTS
(continued)
Section Page
4.1 Remedial Alternatives Identification •••...............•.. 4-2
4.1.1 Alternatives for Offsite Treatment or Disposal •••• 4-2
4.1.2 Alternatives That Comply With All Applicable
And/Or Relevant Public Health And Environmental
standards • • • • • . • . . . • • • • • • • • . • • . • • • • • • • • . . . . . . . . . . . 4-2
4.1.3 Alternatives That Exceeds Requirements of All
Applicable And/Or Relevant Public Health or
Environmental Standards ...••.••••••••.•..••••••••• 4-4
4.1.4 Alternatives That Do Not Attain Applicable
Standards Or Relevant Public Health Or
Environmental Standards, But Will Reduce The
Likelihood or Present or Future Threat From
Hazardous Substances or Pollutants and
Contaminants • • • • . . . . . . . . • • • • • • • . . . . . • • • • . • . . • . . . . . 4-4
4. l. 5 No Action Alternative • • • • • • . • . • • • • • • • • . . . . • • • • • • • • 4-4
4.2 Applicable or Relevant and Appropriate Requirements .•.••• 4-4
4.2.l Federal Standards and Criteria .••..•..•.•••••••••. 4-6
4.2.2 State Standards and Criteria ..•....••••••••••..••• 4-8
4.2.3 Local Standards and Criteria •.•••••••.••.•.••••••• 4-13
4.3 Approach for Evaluation Of Alternatives •••••.••.••••••••• 4-13
4.4 Identification of Data Requirements •••••..•.••••• · •••••.•. 4-15
5.0 SCOPE OF WORK FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY •••• 5-1
5.1 Objectives of Remedial Investigation/Feasibility Study •• 5-1
5. l. 1 Objectives . • • • • • • • • • • • • • • • • • • • • • • • • • . . • • . • . • • . • • • 5-1
5.2 Remedial Investigation/Feasibility Study Tasks· •••••••••• 5-2
5. 2. 1 Project Planning . • • • • • • • • • • • • • • • • . • • • • • • • • • • • • • • • 5-2
5.2.1.1 Work Plan Memorandum •••••••••••••••••••• 5-2
5.2.1.2 Site Visit .............................. 5-2
5.2.1.3
5.2.1.4
5.2.1.5
5.2.1.6
5.2.l.7
5.2.1.8
5.2.1.9
5.2.1.10
5.2.1.11
Review Existing Data •••••••••••••.••••••
Identify ARARs ••••••••••••••••••••••••••
Identify Preliminary Remedial
Alternatives ••••••••••••••••••••••••••••
Work Plan Preparation ••••••....••..••.••
Quality Assurance Project Plan ••••••••••
Project Operations Plan Preparation •.•..
Data Quality Plan ••••••••••.............
Technical/Financial Management •••••••••
Quality Assurance/Quality Control ••••••
5-2
5-2
5-2
5-3
5-4
5-4
5-5
5-11
5-12
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Section
TABLE OF CONTENTS
(continued)
5.2.2 Community Relations •.•.•••....................•... 5-12
5.2.2.1 Community Relations Plan •••••••••••..•••• 5-13
5.2.2.2 Technical/Financial Management ....•..•..• 5-13
5.2.2.3 Quality Assurance/Quality Control ........ 5-13
5. 2. 3 Field Investigation . . . . • . . . . . • • . • • • • . • . • . . . . . . . . . . 5-11
5.2.3.1 Mobilization/Demobilization ••.•.......... 5-11
5.2.4
5.2.3.2
5.2.3.3
5.2.3.4
5.2.3.5
5.2.3.6
5.2.3.7
5.2.3.8
5.2.3.9
5.2.3.10
5.2.3.11
5.2.3.12
5.2.3.13
5.2.3.14
Interagency Agreements/Subcontractor
Procurement 5-11
Site Survey . • . • • . • . . • . . . . . . • . . . . . . . . . . . . . 5-12
Geophysical Infestation ••••••.•.••••••• ·. 5-15
Soil Sampling • • • . • • • • . . . . . . . . . • • . . . • • . • • • 5-13
Surface Water/Sediment Sampling .•••.••... 5-20
Drum, Tank And Building Sampling ••••..... 5-22
Monitor Well Installation ....•.••••.•••.• 5-23
Ground Water sampling ••••••••••••••••...• 5-28
Aquifer Testing • • • • • • • • . . . . • • . . . . . . . . . . . 5-28
Water Level Measurement ••••••.•••••••••• 5-31
Analytical Procedures •..•.•••••••••••••• 5-33
Technical/Financial Management .........• 5-34
Quality Assurance/Quality Control ..•.... 5-34
Sample Analysis/Validation 5-34
5. 2. 4. l Sample Management • • • • • • • • • • • • • • • • • • • . • • • • 5-34
5.2.4.2 Analytical Laboratory Analyses .....•..•.. 5-35
5.2.4.3 Contract Laboratory Data Validation ..••.• 5-35
5.2.4.4 Technical/Financial Management ••••••••••• 5-35
5.2.4.5 Quality Assurance/Quality Control •••••••• 5-35
5. 2. 5 Data Evaluation ••••••••••••••••••••.•.•••.•••••••. 5-35
5.2.6
5. 2. 5 .1 Data Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35
5.2.5.2 Data Reduction and Tabulation •••••••••••• 5-35
5.2.5.3 Environmental Fate and Transport .•••••••• 5-36
5.2.5.4 Technical/Financial Management ••••••••••• 5-36
5.2.5.5 Quality Assurance/Quality Control ..•.•••. 5-36
Risk Assessment 5-36.
5.2.6.1 Public Health Evaluation ••••••.•••••.••.. 5-36
5.2.6.2 Technical/Financial Management ••••••••••• 5-39
5.2.6.3 Quality Assurance/Quality Control ....•... 5-40
5.2.7 Treatibility Study/Pilot Testing •••••••.••.••••••. 5-40
5. 2. 7. l Report Preparation . . . . . . . . . . . . . . . . . . . . . . • 5-40
5.2.7.2 Technical/Financial Management ..•.....•.. 5-40
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Section
5.2.8
5.2.9
5.2.10
5.2,11
5.2.12
5.2.7.3
Remedial
5.2.0.1
5.2.8.2
5.2.8.3
5.2.8.4
5.2.8.5
5.2.8.6
5.2.8.7
5.2.8.8
5.2.8.9
Remedial
5.2.9.l
5.2.9.2
5.2.9.3
TABLE OF CONTENTS
(continued)
Quality Assurance/Quality Control ........ 5-40
Investigation Reports .................... 5-40
Draft Report Preparation ..••••••••••••••• 5-43
Graphics Preparation . • . • . • . • • • . . • . • . . . . . . 5-41
Technical Review . • • • . • • • • • • • • . • • • • • • • • . • . 5-42
Draft Report Printing/Distribution •••.•.. 5-42
Review Meeting • • • • . . . . . . . . . . . . . . . . . • . • • • • 5-42
Final Report Preparation •.•••......•..... 5-42
Final Report Printing/Distribution •..•... 5-42
Technical/Financial Management ••.•....... 5-42
Quality Assurance/Quality Control •••••••. 5-42
Technologies Screening .••..••••••.••.•••• 5-43
List All Potential Technologies
Technical Feasibility Screening
Environmental and Public Health
5-43
5-43
Screening • • . • . • . . . • . . . • • • • • • • • • • • • • . . . • . . 5-43
5. 2. 9. 4 Coat Evaluation • • • • . • • . . . . • • • • • • • • • • • • • • • 5-43
5.2.9.5 Technical/Financial Management ••••••..••• 5-43
5.2.9.6 Quality Assurance/Quality Control •••••••• 5-43
Remedial Alternatives Evaluation ...•••••••••.•.•. 5-44
5.2.10.1
5.2.10.2
5.2.10.3
5.2.10,4
5.2.10.5
5.2.10.6
5.2.10.7
5.2.10.8
Technical Feasibility •••••••••••...••••• 5-44
Public Health Analysis •...•••••••••••••. 5-44
Environmental Analysis •••••••••••••••••• 5-45
Institutional Affects .••.•.••••••••••••. 5-46
coat Analysis .•..•••••••••••••..•..••••• 5-47
Comparison of Alternatives .••••••••••••. 5-47
Technical/Financial Management •••••••••• 5-48
Quality Assurance/Quality Control ••••••• 5-48
Feasibility Study Reports .••••••••..•..•••••••••• 5-48
5.2.11.l Draft Feasibility Study •••......•••••••• 5-48
5. 2 .11. 2 Public Meeting •••.•.•••••••••..••••••••• 5-48
5.2.11.3 Final Feasibility Study •••••••.••••••••• 5-48
5.2.11.4 Technical/Financial Management .••••••.•. 5-49
5.2.11.5 Quality Assurance/Quality Control ••••••• 5-49
Post-RI/FS Support •••••••..•.•••••••..••••••. , • • • 5-49
5.2.12.1
5.2.12.2
5.2.12.3
5.2.12.4
Conceptual Design Report •••••••••••••••. 5-49
Public Meetings • • . . . • • • • • . . . . . • • • • • • • • • • 5-49
Responsiveness Summary .................. 5-49
ROD Preparation/Briefings •...•.........• 5-49
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TABLE OF CONTENTS
(continued)
Section Page
5.2.12.5 Technical/Financial Management •......•.• 5-50
5.2.12.6 Quality Assurance/Quality control ••...•• 5-50
6.0
7.0
SCHEDULE ...................................................... 6-1
STAFFING ...................................................... 7-1
7.1 Project Organization •..••••••..••••••••..•••....••••.•..• 7-1
7.2 Project Responsibility .•.....••••...••.••....•.•.......•• 7-3
8.0 SPECIAL EQUIPMENT NEEDS ••••••.••••••••....••.••...•......••••. 8-1
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LIST OF FIGURES
Figure
2-1 Location Map ..........••.•.•....•....•........................ 2-2
2-2 Site Location Map ••••••••••••.••.••..•..•.•.•••............••. 2-3
3-1 Site Map .....•............................•••••.•.•.......••.• 3-2
3-2 Approximate Locations of Inventoried Water Wells in Table 3-1 . 3-6
3-3 Approximate Locations of Water Wells Sampled in March 1979 ...• 3-9
3-4 Locations of Soil Sampling Points ••.•........................• 3-10
5-l Soil Boring Locations ••..•....•....•....•.••.••••••••••••.•••• 5-17
5-2 Grid and Soil Sampling Locations ....•........•..••......•••..•. 5-1B
5-3 Additional Soil Sampling Locations •....•....•..••••........... 5-23
5-4 Surface Water/Sediment Sample Locations •.••••••••••••••.••.••• 5-24
5-5 other Areas Requiring Sampling •.•••....•••••.•.•.•..••..•.•••• 5-26
5-6 Proposed Monitor Well Locations ..•...........•...•............ 5-27
5-7 Cluster Well Construction •••••••••••••••••••.••..••...•.•..... 5-2B
5-B Groundwater Sampling Locations .•••....•...•.••.•.•...•..•••••• 5-32
5-7 Water Level Measurements . • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 5-32
6-1 Schedule of Activities 6-2
7-1 Project Organizational Chart •••••••••••••••••••••••••••••••••• 7-2
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LIST OF TABLES
Table Page
3-l Water Well Inventory (Generated December 1983) .........••..... 3-4
3-2 Sampling Locations for Samples Collected in March 1979 3-8
3-3 Surface Water/Groundwater Analytical Data for Samples
Collected in March 1979 . • • • • • • • . . • . . • • • • • . . . • • • . . . . . . . . . • . . • . . 3-ll
3-4 Surface Water/Groundwater Analytical Data for Samples
Collected in November 1978 •••.........•.. , .•.•••........•••.•. 3-12
3-5 Soil Analytical Data for Samples Collected in March 1979 ..•••• 3-13
3-6 Soil Analytical Data for Samples Collected in June 1984 3-15
3-7 Sampling Locations Description for Samples Collected in
August 1978 ••••.•••••••••.•••.•..•••••••...••••••.......•••••. 3-16
3-8 Soil Analytical Data for Samples Collected in August 1978 ••••• 3-17
4-1 Potential Methods of Site Remediation •••.••••••••••.••••••••.• 4-3
5-1 Data Quality Objectives . . . • • • • • • • • • . • • • • • • • • . . • • • • • • • . • . . . . • • • 5-6
5-2 Soil Sampling Analytical Parameters ••••••..•••••••••....•.•••• 5-20
5-3 Surface Water/Sediment Sampling Analytical Parameters ..•..••.• 5-23
5-4 Groundwater Sampling Analytical Parameters .................... 5-33
6-1 Schedule of Deliverables •••••.•••••••••...••••••••••.•••••••.. 6-3
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1.0 EXECUTIVE SUMMARY
This work plan was developed specifically to guide the Remedial
Investigation/Feasibility Study (RI/FS) to be conducted at the Carolina
Transformer Site, located in Fayetteville, Cumberland County, North Carolina.
The Carolina Transformer site occupies 4.8 acres and is located on flat
terrain approximately 3,000 feet east of the Cape Fear River.
The site is just north of East Fayetteville at 301 North Eastern Boulevard
which is north of the intersection of U.S. Highway 301 and River Road. The
surrounding area includes agricultural land, several private homes, small
industrial/commercial establishments, and a sand and gravel operations north
of the site.
During a period of at least fifteen (15) years, beginning in 1967 and running
through 1982, the Carolina Transformer Company (CTC) received, rebuilt and
repaired, and stored electrical transformers filled with polychlorinated
biphenyls (PCBs) laden oil at the site. The site is dotted with concrete
slabs onto which transformers were drained of oil prior to being repaired or
rebuilt. Transformers awaiting or in process of repair were also stored on
the concrete slabs. In or about April 1982, CTC moved its operations to
another location and the site was used primarily for transformer storage up
to 1986. Since 1986, CTC has gone out of business and the site has been
vacant.
The primary objectives of the RI/FS are to provide the data necessary to:
1) define the extent of contamination and evaluate the Carolina Transformer
Site's actual and potential impacts on public health and the environment, and
2) enable the selection of a cost-effective remedial action plan. Major data
gaps for the Carolina Transformer Site which will be addressed include:
• Hydraulic characteristics of the aquifer system,
including flow directions and velocities of the
groundwater;
• The areal and vertical extent of groundwater
contamination and contaminants fate;
• The areal extent of surface soil contamination; and
* The degree of contamination of surface water and
sediments.
Once this data is obtained, a risk assessment can be performed, and the
development of a technologically sound and cost-effective remedial
alternative to cleanup the site can be selected.
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The scope of work for the RI/FS is divided into the following 15 tasks:
1. Project Planning -work efforts related to initiating the remedial
investigation;
2. Community Relations -work efforts related to the preparation and
implementation of the community relations plan;
3. Field Investigation -work efforts related to field work in
implementing the remedial investigation;
4. Sample Analysis/Validation -work efforts related to monitoring and
analysis of the samples after they leave the field;
5. Data Evaluation -work efforts related to the analysis of the data once
they have been verified for acceptable accuracy and precision;
6. Risk Assessment -work efforts associated with assessing the potential
impacts on public health, welfare, and the environment from actual or
potential releases resulting from past activities at the site;
7. Remedial Investigation Report -work efforts related to documentation
of the results once the data have been evaluated and the risk
assessment performed;
8. Treatability Study/Pilot Testing -work efforts related to conducting
pilot, bench scale and treatibility studies;
9. Remedial Alternatives Screening -work efforts related to the selection
of remedial technologies to undergo full evaluation;
10. Remedial Alternatives Evaluation -work efforts related to the detailed
analysis and comparison of remedial alternatives;
11. Feasibility study Reports -work efforts related to the documentation
of the results once the remedial alternatives have been evaluated;
12. Post RI/FS Initiatives -work efforts related to activities occurring
after release of the FS Report to the public;
13. Enforcement Initiatives -work efforts related to enforcement aspects
of the project which support negotiations for remedial
design/remedial action;
14. Miscellaneous Initiatives -work efforts associated with the project,
but which are outside the normal RI/FS scope of work; and
15. Expedited Response Action Planning -work efforts specifically related
to planning expedited response actions to provide interim measures,
if required, prior to the remedial action.
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2.0 INTRODUCTION
2.1 SITE LOCATION AND HISTORY
The Carolina Transformer site is located in Cumberland County, North
Carolina, approximately one mile northeast of Fayetteville at 301 North
Eastern Boulevard which is north of the intersection of U.S. Highway 301 and
River Road (Figures 2-1 and 2-2). The approximate map coordinates are
latitude 35° 03' 08 .. N and longitude 78° 50' 07" w. The surrounding area
includes agricultural land, several private homes, small industrial and
commercial establishments, and a sand and gravel operations north of the
site.
The company began recycling electrical transformers in 1967. Operations
ceased in the early 1980's and the facility is currently vacant. Several
abandoned transformers and unlabeled, full, sealed drums are located onsite.
Major surface waters, the Cape Fear River and associated wetlands, are within
one mile of the site. A small, unnamed tributary drains southwest from the
site into the Cape Fear River.
The surfacial sand and underlying cretaceous sand, silt, and clay aquifer is
the source of water for an estimated 3,000 people who use private wells
within a thiee-mile radius of the site.
In July 1978, North Carolina Department of Natural Resources and Community
Development (NCDNRCD), Division of Environmental Management (DEM) received
complaints from residents of the area around the site. The complaints were
the result of fears on the part of residents that the site was the source of
groundwater PCB-contamination. The complaining residents, at the time of
their complaints, received their drinking water from private wells.
In the course of its transformer rebuilding business, Carolina Transformer
handled and stored large numbers of electrical transformers at the site which
contained oil laden with polychlorinated biphenyls (PCBs). DEM'S 1978
analysis of well water samples (taken from various private wells in the area
of the site) produced no evidence of PCBs but their testing effort did
uncover evidence of chlorobenzene in two wells each of which are located
within 1,000 feet of the site. Shortly after these analyses were completed,
all of the complaining residents but one linked themselves to the City of
Fayetteville water system. The potentially responsible party (PRP) hooked up
this other resident to the public water system. Chlorobenzene is a PCB
carrier agent which is expected to have migrated from the site.
In November 1978 and March 1979, EPA -Region IV obtained and analyzed water
samples from twelve private wells in the vicinity of the site.
concentrations of chlorobenzene were again found in the water samples taken
from the two private wells DEM originally sampled. This confirmed the
presence of chlorobenzene in these wells. Following the completion of the
March 1979 private well sampling project, EPA and the Fayetteville Office of
DEM collected soil and surface water samples from the site. The analytical
results indicated the presence of PCB in the soil in certain areas of the
site.
2-l
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'" ' N
-- - -- -- -- - - -
FIGURE 2-1
SITE LOCATION MAP
CAROLINA TRANSFORMER SUPERFUND SITE
CUMBERLAND COUNTY, NORTH CAROLINA
. .__ __
Carolina Transformer Site
--- - -
-
N I w
---------------FIGURE 2-2 LOCATION OF THE CAROLINA TRANSFORMER SITE WITHIN FAYETTEVILLE , NORTH CAROLINA
0
1957
PHOTOHE.vrSF.D : 982
OMA :\154 Ill SE -SERIES V841
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. ... . . ••
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In March and April 1982, DEM drew two surface water samples from the same
locations used in 1979 in the tributary that flows near the site. Analysis
of these samples disclosed PCB contamination of 15 and 40 micrograms/liter
(ug/L) or parts per billion (ppb). A third surface water sample was taken by
DEM in February 1983, and a PCB concentration of 35 ug/L was confirmed by
analysis. Soil samples were obtained by EPA from the site and neighboring
properties in June 1984. Analysis of these samples showed PCB (Arochlor
1260) concentrations ranging from 106 milligrams/Kilogram (mg/Kg) or parts
per million (ppm) to 9,500 mg/Kg. One of the June 1984 samples also
contained Arochlor 1242 at a level of 14,800 mg/Kg. The samples were taken
from depths of 3 to 4 inches below the ground surface.
Prior to EPA's emergency response in August 1984, the geological
circumstances of the site made for the high probability of PCB migration from
the site to the Cape Fear River and into the groundwater in the area
surrounding the site. The site is located in an area which is generally
low-lying and swampy. After any substantial rainfall, water tends to stand
in pools on the site. Soil and surface water sample analyzes confirmed the
presence of the PCBs in the soil and surface water of the site.
Presently, surface water drains from the site into an 18-inch culvert which
runs along the southwest edge of the site. The culvert carries the surface
water to a natural stream channel which measures roughly 24 inches in width.
The stream channel flows through a nearby swampy area into the unnamed
tributary, which is approximately four feet wide. The water flow from the
tributary proceeds to the Cape Fear River at a point not quite two miles from
the site.
Although the area immediately surrounding the site is sparsely populated, the
soil and surface water tests conducted by DEM and EPA in January and March
1979, the high probability of PCBs leaching and migrating into the
groundwater and the close proximity of the Cape Fear River presented, a high
degree of risk to the health of residents in the area of the site and to the
environment. The data generated indicated that over one acre of the ground
surface of the site was contaminated with PCBs at concentration levels in
excess of 50 mg/kg.
In 1979, after the EPA-DEM soil and surface-water testing project showed
conclusively the presence of PCB contamination in the soil and surface water
of the site, Carolina Transformer hired an engineering firm to prepare a
proposal for removal of contamination from the site. By letter dated August
22, 1979, EPA notified Carolina Transformer that removal of PCBs from the
site would not be required. The Agency's rationale was that the release of
PCBs at the site had occurred prior to April 18, 1978, the effective date of
the Toxic Substances control Act (TSCA).
Carolina Transformer continued to operate the site as a transformer
rebuilding factory but made no effort to remove or control the contaminated
condition of the site.
2-4
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Following its March and April 1982 surface water sampling and finding of PCB
concentrations of 15 and 40 ppb, respectively, in the tributary that flows
near the site, DEM attempted to obtain Carolina Transformer's voluntary
cleanup of the site. All such attempts failed. On January 27, 1983, DEM
gave Carolina Transformer notice of its intent to proceed with enforcement
action. The State of North Carolina took no further action. The explanation
given by Carolina Transformer for its failure to undertake any cleanup or
remedy of site contamination was that such an effort would be
cost-prohibitive.
On March 5, 1984, EPA, Region IV issued a CERCLA Section 106 Administrative
Order naming Carolina Transformer as the sole respondent. The order required
the company to remove and dispose of PCB-contaminated soils at an approved
hazardous waste facility. Soil removal was required to the extent that the
total concentration of remaining PCBs was reduced to 50 mg/kg, Installation
of a clay cap over the surface left by excavation was also required under the
order. Carolina Transformer made no response to the order.
Upon consideration of the high concentration levels of PCBs at the site and
the high probability of PCBs migrating, via surface water drain-off, to the
Cape Fear River and into the groundwater, immediate removal action was begun
on August 13, 1984.
Cleanup consiste~ of dewatering the contaminated swampy area ·of the site
where PCB-contaminated surface water pooled and soaked into the soil.
Excavation and solidification of remaining PCB/oil sludge and proper off-site
disposal, The excavated areas were back filled with approximately 588 tons
of uncontaminated soil. The immediate removal action was completed on August
22, 1984. Approximately 975 tons of PCB contaminated material was removed
from the site and transported to the Chemical Waste Management disposal
facility in Emelle, Alabama.
2,2 SITE STATUS
The site has been vacant since 1986, Several potentially responsible parties
(PRPs) have been identified in the PRP search completed by Versar, Inc. in
OCtober 1985. The PRPs contacted by the Agency were Dewey K. Strothers,
Kenneth R. Strothers and the Carolina Transformer Company.
In September 1987, EPA issued notice letters to the PRPs informing them of
EPA's intention.to conduct CERCLA remedial activities at the site unless the
PRPe chose to conduct such actions themselves. The notified PRPs declined to
voluntarily conduct an RI/FS which resulted in the Agency initiating an
in-house study. Ae stated previously, the purpose of the RI/FS is to provide
the data necessary to evaluate the Carolina Transformer site's actual and
potential impacts on public health and the environment and to allow the
selection of ae cost-effective remedial action.
2-5
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2.3 OVERVIEW
Based on a detailed review of the existing site information in the Agency's
files and site inspection visits on May 25, 1988 and August 31, 1988, an
initial evaluation of the site was developed, which can be found in
Section 3.
Section 4 provides a preliminary assessment of remedial alternatives, which
includes the spectrum of potential remedial options applicable for the site,
and outlines performance criteria and standards.
Section 5 outlines the RI/FS scope of work which includes the objectives and
rationale of the RI/FS tasks and reporting requirements.
2-6
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3.0 INITIAL SITE EVALUATION
3.1 SITE DESCRIPTION
The area surrounding the site is generally low-lying and swamp-like in
character. The site, itself, is situated in the path of, or very near the
headwaters of an unnamed tributary which flows less than two (2) miles from
the site to the Cape Fear River. Therefore, surface water from the site
flows directly to the Cape Fear River. The major structures on the site are
depicted in Figure 3-1. The site also lies within the 100 year flood plain
for the Cape Fear River.
3.1.1 ENVIRONMENTAL SETTING
3. 1. 1. 1 ·Geology
The Fayetteville area lies within the Flatwoods section of the Coastal Plain
physiographic province. The area is described as a plain gently dipping to
the southeast drained by large, sluggish streams having swampy floodplains.
The streams have developed a dendritic drainage pattern (Schipf, 1961).
The Carolina Transformer Site lies upon an alluvial terrace approximately 3/4
miles east of the Cape Fear River. The Site is underlain by alluvial
deposits of Quaternary age and the Tuscaloosa Formation of cretaceous age.
The Tuscaloosa is the basal Coastal Plain formation resting directly on rocks
of the volcanic slate series. The Tuscaloosa Formation is mainly a massive
clay containing interbedded layers of sand and has been reported to be
approximately 250 feet thick in the Fayetteville area (Schipf, 1961). In
surface exposures, the Tuscaloosa has been described as a series of beds of
loose to fairly well-consolidated sandy clay with loose sand and occasional
exposures of massive kaolin. The Tuscaloosa is overlain by alluvial deposits
of the Cape Fear River. These deposits rarely exceed 50 feet in thickness
and consist of gravel, sand, silt, and clay and mixtures of these with silt
and clay as the chief constituents (Schipf, 1961). Local well logs indicate
that clay predominates within the alluvial deposits of the terrace area near
the Cape Fear River (Worrell, Personal communication).
Site Specific Geology
The surfacial soils at the Site consist of the Wickham Series and.the Roanoke
Series. Wickham Series soils cover most of the former facility area. These
are well-drained soils that formed in loamy fluvial sediments on terraces of
the Cape Fear River and its major tributaries. The loamy horizon is
typically 40 ·to 60 inches deep and is underlain by sandy alluvial sediments.
The organic matter content ranges fro~ 0.5 to 2 percent (Hudson, 1984).
Roanoke Series soils cover the wooded area northwest of the former facility
area. These are poorly-drained soils that formed in stratified clayey
sediments on terraces of the Cape Fear River and its major tributaries. The
loamy and clayey horizons are generally 40 to 60 inches deep and overlie the
stratified sediments deposited by the river. The organic matter content
ranges from 0.5 to 3 percent (Hudson, 1984).
3-1
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3.1.1.2 Hydrogeology
The Carolina Transformer Site may be underlain by as many as three aquifers.
The alluvial deposits where sands and gravels are present could provide large
yields to wells. The available information indicates that the alluvial
aquifers are not presently used for water supply in the area. The sands and
clays of the Tuscaloosa Formation serve as aquifers in the Fayetteville
area. Wells completed within this formation can be screened over a large
interval which could cover sands and intervening clays. The sands provide
much higher yield and are the most productive aquifers in the region (Schipf,
1961). The bedrock possesses fracture permeability and is utilized for
industrial supplies. A deep bedrock well is used by Larry's Sausage Company
which is located adjacent to the Site. This well is 303 feet deep and is
completed into bedrock from 212 feet to the total depth.
Ground-water flow at the Site is controlled by local surface-water bodies.
The Cape Fear River is a major discharge point for all of the aquifers.
Locks Creek will influence ground-water flow in the uppermost aquifers at the
Site. Domestic wells are utilized for supply in this area.
A water budget performed for the Site using 45.56 inches of precipitation per
year resulted in 31.14 inches of evapotranspiration and 3.47 inches of
runoff. The remaining 10.95 inches per year is recharge to the water table.
3.1.1.3 Climate
The average annual precipitation of 45;5 inches is fairly evenly distributed
throughout the year. Historically, March is the wettest month of the year
and September through December are drier than the spring and summer months.
over an annual period, average monthly temperatures range from 40 degrees
Fahrenheit in January to 78 degrees Fahrenheit in July. The warm summer
temperatures combined with heavy precipitation in these months maintains a
humid environment.
3.1.2 REVIEW OF EXISTING DATA BASE
3.1.2.1 Groundwater
Monitor Well Data
Presently, these is no monitor well data.
Oomestic Well Data
North Carolina Department of Natural Resources & Community Development
(NCDNRCD) conducted a domestic well inventory in the vicinity of the site in
December 1983. In a telephone conversation with a NCDNRCD official in
october 1988, it was confirmed that this brief December 1983 well survey has
not changed. Table 3-1 lists results of the 1983 private well inventory and
Figure 3-2 provides the approximate locations of the inventoried wells.
3-3
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I Well No.
(with
I respect to
Figure 3-2)
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11
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TABLE 3-1
Water Well Inventory Generated by
North Carolina Department of Natural Resources &
Community Development
(Data generated in December 1983)
Designated Owner Approximate Present
Sample as of Depth of Status of
Identifier December 1983 Well If t I Well
NA J.K. Bllis l 2 No longer in use; on
City water system
NA M. I, Ellis 12 No longer in use; on
City water system
F-003 Roger Bllis l 2 No longer in use;
complained of oily
smell/taste of water;
on City water system
F-002/ Bessie Bdge 12 No longer in
CTW-Wl2 use; complained of
oily smell/taste of
water; on City water
system
CTW-W02 Larry's 300 Still in use
Sausage Co.
NA Joe Royster 16. 5 Still in use
NA Alton McDaniel 260 Still in use
BA Robert P. Williama shallow Still in uae
CTW-WOS T. R. Weeks 363 Still in use
CTW-WlO Roadway B:r.press unknown Well went dry; on
Trucking City water system
NA Domestic Shallow Unknown
NA James A. Smith 72 Still in use
3-4
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(with Designated
respect to Sample
I Figure 3-2) Identifier
I 13 NA
14 NA
I 15 NA
I 16 NA
I 18 F-004
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TABLE 3-1
(continued)
Owner Approximate
as of Depth of
December 1983 Well (ft)
L,W, Silly Unknown
Jadie Atkins Unknown
Son of Jamee No well
A, Smith
Daughter of Unknown
Bessie Edge
Charles Vanzant Unknown
3-5
Present
Statue of
Well
On city water system
On city water system
On city water system
On city water system
Still in use
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Table 3-2 furnishes brief descriptions of the samples collected by EPA in
March 1979. The locations of these sampling points can be found in Figures
3-3 and 3-4 with Tables 3-3 and 3-4 providing the analytical results.
The private potable wells abandoned due to chlorobenzene contamination and
the wells of the other residents who hooked up to the public water supply
system were shallow wells. They ranged in depth of 10 to 20 feet. Larry's
Sausage Company's well penetrates the bedrock and is a total depth of 303
feet. The company continues to use this well even though the well is
adjacent to the site. Additional data on the other private wells will be
collected during the RI/FS.
Groundwater Flow
It is assumed that the groundwater in each of the three expected aquifers is
flowing towards the Cape Fear River. The shallow aquifer may be influenced,
to an unknown degree, by Locke Creek.
3.1.2.2 Surface Water/Sediment
Classification of the surface waters at and around the site was determined in
accordance to the State of North Carolina Department of Natural Resources and
Community Development, Division of Environment Management -Administrative
Code Title 15, Subchapter 2B, Section 0.0200 dated February 1, 1986. Locks
creek and the unnamed creek that drains the site are classified as Class c
streams. Class C waters are defined as -Best Usage of Waters: Fishing,
secondary recreation, agriculture and ·any enter usage except for primary
recreation or as a source of water supply for drinking, culinary or food
processing purposes. The unnamed stream empties into the Cape Fear River
which is a classified as class WS-II. Class WS-II waters are defined as Best
Usage of Waters: source of water supply for drinking, culinary or food
processing purposes for those users desiring maximum protection for their
water supplies.
Several sediment and surface water samples were collected prior to the 1984
emergency cleanup. The sediment samples are designated CTS-001 and CTS-002.
The loca~ion of these points can be found in Figure 3-4 and the analytical
results are in Table 3-5.
The surface water samples collected at the site are designated F-001, CTW-001
and CTW-002. The locations of these samples points can also be found in
Figure 3-4 with the analytical results presented in Tables 3-3 and 3-4. The
data generated as a result of these samples indicated the was contaminated
with transformer oils and PCBs and that these contaminants had migrated
off-site to an unknown distance.
3-7
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TABLE 3-2
Sampling Loations for Samples Collected
In March 1979 By EPA-ESD
Sample Identifier Sampling Location Description
CTS-001
CTS-002
CTW-001
CTW-002
-F-001
CTW-WOl
CTW-W02
CTW-W03
CTW-W04
CTW-WOS
CTW-W06
CTW-W09
CTW-WlO
CTW-Wll
CTW-Wl2
F-003
F-004
Soil sample from northwest transformer storage area
Soil sample from northwest transformer storage area
Water sample from water pooled at back of northwest
transformer storage area
water sample from water pooled at back of northwest
transformer storage area
water sample from culvert draining the southwest
transformer storage area
Well water, Carolina Transformer Company (previously
designated F-005)
Well water, Larry's Sausage Company
Well water, Borden Dairy
well water, Britt Clayton
Well water, T.R. Weeks
Well water, Phillip Sealey
well water, Charles Davis
Well water, Roadway Bxpress Trucking
Well water, Well'& Blectronics
Well water, Bessie Bdge (previously designated F-002)
Wel 1 water, Roger Bll is
Well water, Charles Vanzant
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E ASTEl?N BLVD
I-IW( 30/ OJ?' 9
JIOLL rwoot,
8.t.YI)
LEGEND
• Well Location
[Not to Scale]
FIGURE 3-3 Approxiamte Locations Of Water Wells Sampled March 27/28, 1979.
3-9
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FIGURE 3-4
I iv1.,;" ,
{){./:.,e,~
Bl~ j ·
ri1 ,dd le f?.,J;
0
1
Schematic Diagram Locating Soil Sampling Points.
3-10
LEGEND
• sampling Point
(Not to Scale)
- - - --- -- - - -- --TAllLB 3-3
Paet Analytical Data Generated at
Water Sample
CTW-001
CTW-002
CTW-WOl
CTW-W02
CTW-WO)
CTW-W04
CTW-W05
CTW-W06
CTW-W09
CTW-WlO
CTW-Wll
CTW-W12
Dichloro-
benzene
(2 isomers)
( ug/L)
RD(0.81)
7.8
ND(0.11)
ND(0.05O
RD(D.056)
ND(0.056)
ND(0.056)
ND(0.056)
ND(0.056)
ND(0.056)
ND(0.056) • •••
1,2,, Tri-1,2,3 Tri-
chlorobenzene chlorobenzene
(ug/L) (ug/L)
1.0 o. 22 • • 49 8.1
8D(0.0072) lrfD(0.0072)
ND(0.0036) RD(0.0036)
ND(0.0035) ND(0.0035)
80(0.0035) ND(0.0035}
RD(0.0036) ND(0.0036)
RD(0.0035) RD(0.0035)
RD(0.0035) ND(0.0035)
ND(0.0036)
ND(0.0036) • ,o
ND{0.0036)
ND(0.0036) • 26
Samples were collected in March 1979.
the Carolina Transformer Site
Tetrachloro-
benzene
(2 isomers)
(ug/L)
, .. • 17
ND(0.0022)
ND(0.0011)
ND(0.0011)
ND(0.0011)
ND(0.0011)
ND(0.0011)
ND ( 0. 0011)
ND(0.0011)
ND(0.0011) • 5.2
Pentachloro-
benzene
(ug/L)
2.6
1.1
ND(0.0043)
ND(0.0021)
ND(0.0022)
ND(0.0022)
ND(0.0021)
ND(0.0022)
ND(0.0022)
ND(0.0021)
ND(0.0021) • 0.19
ND -None detected. Numbers in parenthesis are the minimum detection limits.
NA -Not analyzed.
* -Con!irmed by GC/Maaa Spectrometry.
Bexachloro-
benzene
(ug/L)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
- -
Aroclor
1242
(ug/L)
80 • 5,800
ND(0.079)
ND(0.040)
ND(0.038)
ND(0.038)
ND(0.040)
ND(0.036)
ND(0.038)
ND(0.040)
ND(0.040)
ND(0.19)
-
Aroclor
1260
(ug/L)
3,000 .
4,700
-
ND(0.10)
ND(0.051)
ND(0.053)
ND{0.053)
trace <0.03
ND(0.052)
ND(0.053)
ND(0.051)
ND(0.051)
ND(0.52)
-
-
w
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N
- -- ---- ---- - -
TABLE 3-.f.
Past Analytical Data Generated at
the Carolina Transformer Bite
Dichloro-Tetrachloro-
benzene 1,2,4 Tri-1,2,3 Tri-benzene Pentachloro-Bexachloro-
Water Sample (2 ieomera) chlorobenzene chlorobenzene (2 ieomere) benzene benzene
(ug/L) { ug/L) (ug/L) (ug/L) (ug/L) (ug/L)
F-001 RD(2.0) 2.2 Trace <0.74 2.0 ND(l.6) NA
F-002 16 11 32 12 ND(2.0) NA
F-003 o.o, 0.02 0.006 0.01 ND(0.006) NA
F-004 RD(0.012) 0.03 1.0 0.01 ND(0.006) NA
F-005 RD(0.015) 0.02 Trace <0.004 0.01 Trace <0.007 NA
Samples collected in November 1978.
ND -None detected. Number■ in parenthesis are the minimum detection limits.
NA -Not analyzed.
- -- - -
Aroclor Aroclar
1242 1260
(ug/L) (ug/L)
ND(l2) 940
ND( 14) NO(JJ)
ND(0.06) ND(0.16)
ND(0.05) ND(0.15)
ND(0.07) Trace <0.19
-
w I
~ w
-- -- -- - -- - - - -
TABLE 3-5
Past Analytical Data Generated at
the Carolina Transformer Site
soil Sample
CTS-001-sur
CTB-001-3"
CTS-001-6"
CTB-002-sur
CTS-002-3"
CTS-002-7"
Dichloro-
benzene
(2 ieomere)
(mg/Kg)
0.075
RD(0.020)
RD(0.016)
ND(l.O)
ND(0.94)
ND(0.45)
Sample ■ collected in March 1979.
1,2,4 Tri-1,2,3 Tri-
chlorobenzene chlorobenzene
(mg/Kg) (mg/Kg)
0.057 0. 012
0.14 0.030
HD(0.0034) ND(0.0034)
13 2.9
3.0 0.75
0.96 0.22
Tetrachloro-
benzene
(2 isomers)
(mg/Kg)
0.18
1.4
ND(0.0022)
5.6
1.0
0.25
ND -None detected. Number ■ in parentheeia are the minimum datection limits.
NA -Not analyzed.
• -confirmed by GC/Maaa Spectrometry.
Pentachloro-
benzene
(mg/Kg)
0.061
0. 2 2
N0(0.011)
0.74
0.21
RD(0.10)
- -
Bexachloro-
benzene
(mg/Kg)
NA
NA
NA
NA
NA
NA
-
Aroclor.
1242
(mg/Kg)
24
0. 16
0.0041
4200
1200
210
- -
Aroclor
1260
(mg/Kg)
2 60
22
0.060 • 1100
200
5B
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3.1.2.3 Soil
The analytical results for the soil samples collected during the emergency
cleanup operation in June 1984 are presented in Table 3-6. These samples
were taken from the area remediated, the swampy area north of the site.
Following removal of the contaminated soils, the excavated area was
backfilled with clean fill.
3.2 CONTAMINATION PROBLEM DEFINITION
3.2.1 WASTE DISPOSED OF ON-SITE
In an attempt to characterize·the materials on-site and determine if PCSs
were present at the facility, several miscellaneous samples were .collected in
August 1978 by EPA-ESD. The locations of the samples are described in
Table 3-7 with the analytical data presented in Table 3-8. As can be seen
from the data in Table 3-8, Arochlor 1242 and Arochlor 1260 were presented at
the site.
Due to what appears to be the careless handling of oils from the transformers
during the active years of the facility, significant quantities of the oil
were split or discharged to the ground. Presently, the holding tanks on-site
appear to be partially filled with an unknown material. It is assumed that
the material is transformer oil containing PCBs.
3.2.2 TOXICITY OF CONTAMINANTS
Contaminants that have been consistently detected at levels high enough to be
considered a public health or environmental concern are polychlorinated
biphenyls, dichlorobenzenes, 1,2,4-trichlorobenzene, and pentachlorobenzene.
Below are descriptions of these compounds:
Polychlorinated Biphenyls
Description: c 12a 10_xClx, diphenyl rings in which
one or more hydrogen atoms are replaced by a chlorine
atom.
Code Number: CAS 1336-36-3
Polychlorinated biphenyls (PCBs) are a class of complex
molecules composed of paired phenyl rings substituted
with varying amounts of chlorine. The trade name for
PCBs, produced in the United States, is Arochlor, which
was produced primarily by Monsanto. The last two
digits of the series number indicate the percentage of
chlorine in the molecule, for example, Arochlor 60 is
approximately 60 percent chlorine by weight.
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Soil Sample
ss 1
ss 2
ss 3
ss 4
ss 5
ss 6
ss 7
ss 8
ss 9
ss 10
ss 11
TABLB 3-6
Past Analytical Data Generated at
the Carolina Transformer Site
Fayetteville, North Carolina
Aroclor 1242
(mg/Kg)
14,500
Aroclor 1260
(mg/Kg)
5,400
352
l, 2 6 0
1 06
4,860
1,070
1,640
940
755
2,120
9,500
Total Aroclor
(mg/Kg)
20,200
352
1,260
106
4,860
1,070
l, 6 4 0
940
755
2,120
9,500
Samples were collected June 1984 during emergency cleanup operations.
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Sample No.
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NC-001
I NC-002
I NC-003
I NC-004
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TABLB 3-7
Description of Sampling LoCations for
August 1978 Sampling Episode
Sampling Location
Old blue Ford gas truck (full), silver tank, no
license tag, capacity approximately 2,000 gallons
Tanker truck (white), no license tag, capacity
approximately 5,000 gallons
Old transformer used for oil storage, capacity
approximately 2,000 gallons
Yellow drum half-full, capacity 55 gallons, marked
•transformer pyranol -Monsanto -Pee•.
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--- - - -- - - - - - -
TABLE 3-8
Past Analytical Data Generated at
Soil SalDple
NC-001
NC-002
NC-003
NC-004
Dichloro-
benzene
( 2 isomers)
(mg/Kg)
ND ( 2)
ND(l.9)
0.22
ND(50,000)
1,2,4 Tri-
chlorobenzene
(mg/Kg)
11
61
5.7
279,000
1,2,3 Tri-
cbloroben:r:ene
(mg/1::g)
2. 5
10
1.1
85,000
samples were collected in August 1978 by EPA-BSD.
ND -None Detected (minimum detection limit in parenthesis).
the Carolina Transformer Site
Tetrachloro-
benzene
(2 isomers)
{mg/Kg)
2.2
•• 5
0.37
147,000
Pentachloro-
benzene
(mg/Kg)
3.6
<0.22
0. 21
12,000
- - -
Hexachloro-
benzene
(mg/Kg)
ND ( 1. 6)
ND(0.2)
HD(O.l)
ND(4,000)
Aroclor
1242
(mg/Kg)
ND ( 15)
14 0
ND ( 0. 6)
ND(37,5000}
"t-? cl. l
- -
Aroclor
1260
(mg/Kg)
20
130
5. 3
ND(63,000)
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PCBs have become ubiquitous in the environment because
of their resistance to biochemical degradation and
their widespread use. They are widely dispersed in
water, sediments, and in many foodstuffs, and are known
to accumulate in tissues of fish and other aquatic
organisms. It has been estimated that the average
intake of PCBs by a young male in the United States
ranges between 10 and 20 micrograms daily (DHEW et al.
1977).
Qualitative Description of Health Effects
Assessment of the health risks posed by PCBs can be
difficult. PCB is a generic term used to apply to a
number of commercial products, all of which are complex
mixtures of chlorinated biphenyls. These products vary
substantially in their composition and differ in their
toxicity. In addition, PCBs are subject to
contamination with highly toxic impurities which may
form during use and can greatly increase the potency of
the mixture.
Current Criteria
EPA established an ambient water quality criterion for
PCBs based on the production of liver tumors in rats.
The criterion describes a unit risk of cancer of 4.34
milligrams/kilogram/day (mg/Kg/day·)-1 • This unit
corresponds to an excess risk of 10-5 associated with
lifetime consumption of fish from water contaminated
with 0.79 nanograms/liter (ng/L) of PCBs (EPA, 1960).
Analysis of Current Criteria
Cordle et al. (19B2) suggested a tolerance limit for
PCBs in fish of 2 parts per million (ppm). The
partition coefficient between fish and water is about
106 for PCBs, and therefore the maximum water
concentration suggested by the Cordle et al. is about 2
ng/L. Thie compares favorably with the 10-5 risk
calculated by EPA. Most regulatory agencies consider a
risk range of 10-5 to 10-6 to be acceptable and
most federal regulations for environmental contaminants
(incorporating consideration of costs and feasibility)
have generally fallen into the 10-4 to 10-6
lifetime risk range (EPA 49 CFR 24348, 1984).
Routes of Entry: Inhalation of fume or vapor and
percutaneous absorption of liquid, ingestion, eye and
skin contact.
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Harmful Effects and Symptoms (HTHCC, 1985): Local -
Prolonged skin contact may cause the formation of
chloracne. Irritation of eyes, nose and throat may
also occur. The above standards are considered low
enough to prevent systemic effects, but it is still not
known whether or not these levels will prevent local
effects.
Systemic -Genreally, toxic effects are dependent upon
the degree of chlorination; the higher the degree of
substitution, the stronger the effects. Acute and
chronic exposure can cause.liver damage. Signs and
symptoms include edema, jaundice, vomiting, anorexia,
nausea, abdominal pains, and fatigue. Studies of
accidental oral intake indicate that chlorinated
diphenyls are erobryotoxic, causing stillbirth, a
characteristic grey-brown akin, and increased eye
discharge in infants born to women exposed during
pregnancy.
Certain polychlorinated biphenyls are carcinogenic in
mice and rats after oral administration, producing
liver tumors (IACR, 1974, 1978).
A slight increase in the incidence of cancer,
particularly melanoma of the skin, has been reported in
a small group of men exposed occupationally to Arochlor
1254, a mixture of polychlorinate biphenyls (IACR,
1974, 1978 and IACR, 1979)
Points of Attack: Skin, eyes, liver.
Dichlorobenzene
Description: c 6H4c12 , there are three isomeric
forms;
Name
1,2-dichlorobenzene
l,3-dichlorobenzene
1,4-dichlorobenzene
Code Number
CAB 95-50-1
CAB
CAB
none
106-46-7
Routes of Entry: Inhalation, ingestion, eye and skin
contact for 1,4-dichlorobenzene. Also skin absorption
for 1,2-dichlorobenzene.
Harmful Effects and Symptoms (HTHCC, 1985): Human exposure
to dichlorobenzene is reported to cause hemolytic
anemia and liver necrosis, and 1,4-dichlorobenzene has
been found in human adipose tissue. In addition, the
dichlorobenzenes are toxic to nonhuman mammals, birds
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and aquatic organisms and impart an offensive taste and
odor to water. The dichlorobenzenes are metabolized by
mammals, including humans, to various dichlorophenols,
some of which are as toxic as the dichlorobenzenes.
For 1,2-dichlorobenzene, irritation of eres a~d ~ose;
live and kidney damage; skin blistering. For
1,4-dichlorobenzene, headaches; eye irritation,
periorbital swelling; profuse rhinitis; anorexia,
nausea, vomiting, weight loss, jaundice, cirrhosis.
Points of Attack: For 1,2-dichlorobenzene -liver, kidneys,
skin, eyes. For 1,4-dichlorobenzene -liver, respiratory
system, eyes, kidneys, skin.
1!2,4-trichlorobenzene
Code Number: CAS 120-82-1
Harmful Effects and Symptoms (HTHCC, 1985): Local -
Chlorinated benzenes are irritating to the skin,
conjunctiva, and mucous membranes of the upper respiratory
tract. Prolonged or repeated contact with liquid
chlorinated benzenes may cause skin burns.
Systemic -In contrast to aliphatic halogenated
hydrocarbons, the toxicity of chlorinated benzenes
generally decrease as the number of substituted chlorine
atoms increase. Basically, acute exposure to these
compounds may cause drowsiness, incoordination, and
unconsciousness. Animal exposures have produced liver
damage. Chronic exposure may result in liver, kidney and
lung damage as indicated by animal experiments
Points of Attack: Skin, eyes, liver, kidneys, lungs.
Pentachlorobenzene
Code Number: CAS 608-93-5
Harmful Effects and Symptoms (HTHCC, 1985): oral feeding
of pentachlorobenzene to pregnant rats has produced
developmental effects and decreased body weights in
fetuses. No adverse reproductive or developmental effects
were seen in mice following maternal administration of the
compound orally. There is no information available on the
mutagenic effects of pentachlorobenzene.
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3.2.3 DEGREE OF SITE CONTAMINATION
The degree of contamination of the site and the study area is detailed in
Section 3.l.2 REVIEW OF EXISTING DATA BASE, which summarizes and presents
results of previous site investigations. Assessing the present degree of
site contamination is difficult due to the August 1984 site cleanup
operations and to the limited amount of data collected both before and after
the removal action.
Past investigations indicated that the site was contaminated with PCBs
(Arochlor 1242 and 1260) tainted transformer oil. To date no other
contam~nants have been analyzed for in environmental samples collected at or
around the site. The analytical data indicates that the PCB laden oil has
migrated off-site to a swampy area north of the site and according to a
conversation with a local resident, the swampy area southwest of the site on
the other side if the driveway has been impacted as well by the contamination
originating from the site. This swampy area is connected to the drainage
ditch that runs along the back side of the site through a culvert that runs
underneath the driveway to the resident's house. Soils on-site are visibly
saturated with oil to an estimated depth of one (1) to two (2) inches.
Both surface water and sediment samples collected have shown PCB
contamination. Samples collected to date have shown the migration of PCBs to
the culvert-that the ditch along the back of the Carolina Transformer
property line leads to and beyond. The culvert runs underneath the driveway
of the nearest residence to the site. The culvert discharges to a swampy
area southwest of the site that has also show PCB contamination.
Of the 12 private residential/commercial wells sampled in the vicinity of the
site, only two (2) were found to be contaminated. The contaminants found in
both wells were chlorobenzenes which are carrier compounds for PCBs.
Extensive sampling will be conducted during this remedial investigation to
determine the present degree and extent of site contamination.
3.3 CONTAMINANT MIGRATION AND ENVIRONMENTAL HEALTH EFFECTS
The purpose of this section is to provide a preliminary assessment of
potential pathways for contaminant migration off-site, to identify potential
receptors, and to assess the potential environmental and health effects to
receptors. In order to adequately address these issues, the basic
hydrogeological characteristics of the site and demography of the area must
be well defined. The demographic characteristics of the area are fairly well
defined; however, the hydrogeologic characteristics of the site can only be
addressed in general terms from known site characteristics. Data gaps in the
hydrogeology of the site will be filled during proposed remedial
investigation.
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3.3.1 MIGRATION PATHWAYS
3.3.1.1 Constituent Pathway and Transport Evaluation
A constituent pathway and transport evaluation will be conducted to include
soil (unsaturated zone), groundwater, surface water and air. The evaluation
developed under this section will be used as the basis for the work to be
conducted under the Public Health and Environmental Assessment.
3.3.1.2 Unsaturated Zone
Numerous soil samples will be collected during the on-site remedial
investigations. The soil sampling is described in detail in the site
sampling plans of this work plan. The type of information that will be
collected (from infield sampling results and the technical literature) and
used to evaluate constituent pathways and transport pathways includes the
following:
* The type of constituents present;
* The extent the constituents have migrated;
* Constituent solubility and density;
* Constituent amenability to soil absorption/adsorption; and
* Volatility of constituents.
This type of information will allow an initial determination as to whether
waste or waste constituents are being transported through the unsaturated
soil zone into groundwater or are being attenuated in the soil.
3.3.1.3 Groundwater
Of the two (2) major pathways for the migration of contaminants off-site,
groundwater or surface water, migration of contaminated groundwater is most
likely to have the greatest impact on public health.
Groundwater sampling will also be conducted during the on-site remedial
investigations. Information gained through groundwater sampling may allow
delineation of the type and extent of waste constituent concentrations in the
ground water depending upon the primary constituents of concern. Specific
characteristics, such as solubility and density, in conjunction with
hydrogeologic data, such as soil hydraulic conductivity, will allow initial
determination of:
* Projected direction and rate of transport in the groundwater;
* Determination of whether waste constituents would collect at the
interface of the aquifer surface and the unsaturated soil zone or settle
through the aquifer and become concentrated along the surface of the
underlying bedrock; and
* Whether waste constituents are likely to percolate through the soil and
be leached out and subsequently transported into the underlying aquifer.
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3.3.1.4 Surface Water
Surface water is an important mechanism for the transport of contaminants
off-site. This pathway may be influenced by discharge or leachate or
contaminated groundwater, and by erosion of contaminated soils. Due to the
shallow water table, the surface and groundwater may be in direct contact in
some locations. As can be seen in Section 3.1.2.2, contaminants have entered
the on-site drainage system directly from surface runoff from the work area.
An off-site swampy area which is connected via a culvert to the on-site
drainage ditch receives the surface runoff. Surface water may be a migration
pathway directly via the drainage system or indirectly through leaching into
the groundwater. surface water and sediment sampling will be conducted
during the remedial investigation.
Therefore, surface water sampling will also be conducted during the remedial
investigations. This will allow for an initial determination of off-site
migration of waste constituents. Migration could be occurring by one of the
following pathways:
* Recharge of surface streams with ground water and
* Storm water runoff from the site.
3. 3. 1. 5 Air
contaminants may be transported off-site via air currents either as
particulates or organic vapor. No extensiye air monitoring has been done at
the site. Air is not anticipated to play a significant role in either the
migration of contaminants at the site or exposing workers at the site to
unsafe levels of contaminants. The emergency cleanup in August 1984 included
the backfilling of those areas where the most contaminated soils were removed
and replaced with clean fill dirt. Thie help will reduce the risk of
contaminant migration from the site via airborne particulates.
Air monitoring either via photo-ionization detector (HNu) or flame ionization
detector (OVA) or both will be conducted as part of the health and safety
program during appropriate field activities. An air sampling task will be
undertaken if the presence of significant concentrations of organic vapor is
de.tected during the course of the field investigation.
The following action levels will be used to determine when working conditions
on-site become unsafe or an up grade to a higher level of protection is
warranted.
o 0-5 ppms above established background -Level D
Protection will be Adequate
o 5-25 ppms above established background -Level c
Protection will be required
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o 25-50 ppms above established background -Level B
Protection will be required
o >50 ppms above established background -Evacuate the
site and re-evaluate
The details will be specified in the Health & Safety Plan.
3.3.2 PUBLIC HEALTH AND ENVIRONMENTAL ASSESSMENT
A Public Health and Environmental Assessment will be conducted to establish
the extent to which constituents which are present at the site or which may
have been released from the site present a hazard to public health or the
environment. Thia assessment will evaluate conditions at the site in the
absence of any further remedial actions, ·1.e., it will constitute an
assessment of the "No-Action" remedial alternative. This assessment will be
based on procedures provided in the US EPA Superfund Public Health Evaluation
Manual (EPA 540/1-86-060) and the US EPA Guidance on Feasibility Studies
Under CERCLA (EPA 540/G-85-003).
3.3.3 HEALTH ASSESSMENT
As mandated by the Superfund Amendment and Reauthorization Act of 1986, the
Agency for Toxic Substances and Disease Registry (ATSDR) of the U. s. Public
Health Services is task with conducting a Health Assessment for each
Superfund site. The Health Assessment will be incorporated into the Record
·of Decision.
3.3.4 POTENTIAL RECEPTORS
Potential receptors have been tentatively identified based on two field trips
conducted in May 1988 and August 1988 to the site and various individuals in
and around the site and at the local and state government level.
Potential receptors could include groundwater users, surface water users and
aquatic life downgradient from a site. Based on field observations, the
number of potential groundwater users that.could be affected by any of these
sites is small. Groundwater is no longer the source of drinking water for
the residents immediately downgradient of the site as they are now obtaining
their potable water from the City of Fayetteville. No other private
residential well is anticipated to be affected by the site since groundwater
is anticipated to be discharging into caper Fear River and there are no
residents between the site and the river. Groundwater users and receptors
will be identified during the RI.
Surface water users and aquatic life downgradient from the site are also
potential receptors. Testing of surface waters and sediments downgradient of
the site is a major task of the RI.
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3.3.5 ENVIRONMENTAL AND PUBLIC HEALTH EFFECTS
The primary pollutant of concern at the site is the PCB, Arochlor 1242 and
1260. Arochlor 1260 contains the highest percentage of chlorine of any of
the PCB series and is the most recalcitrant. PCBa are widely dispersed in
water, sediments, and in many foodstuffs, and they are known to
bioaccumulate, by orders of magnitude, in tissue of aquatic organisms.
Consumption of contaminated fish tissues and other macroinvertebrate tissues
is a major source of exposure of the public to PCBs.
Freshwater residue data shows that PCBs accumulate to relatively high levels
in vertebrate and invertebrate tissues and that for most species, PCBs are
not rapidly depleted when exposure is discontinued. Bioconcentration factors
for freshwater invertebrate species range from 2,700 -108,000.
Bioconcentration factors for PCB exposures of fish species range from 3,000 -
274,000 (EPA, 1980). Acute toxicity of PCBs varies considerably among
freshwater species. The following are several examples of Lc50 values for
various species (EPA, 1.980).
Species Concentration
Gammarus fasciatus (scud) 10 ug/L
Ischnura verticalis (damselfly) 400 ug/L
Pimephales promelas
(fathead minnow) 7.7 ug/L
Micropterus salmoides
(large mouth bass) 2.3 ug/L
Tanytarsus dissimilis (midge) 0.08 ug/L
Daphnia magna (water flea) 2.1 ug/L
* Arochlor 1254 (54\ chlorine)
Specifics
96-hr LC50, static
96-hr Lc50, flow through
96-hr Lc50 , flow through
96-hr Lc50 , flow through
96-hr LC50, flow through
96-hr LC50' static
In humans, PCBs are measurable in the blood, organs, and fat of some
percentage of the "normal" population. In a study of a population in South
Carolina, PCBs were measured in rural and urban.blacks and whites. The
prevalence of detectable levels ranged from a low of 5\ in rural blacks to a
high of 62\ in rural whites, and average levels in these groups ranged from
about 4-10 ppb (DHEW, 1977). In Bloomington, Indiana, Baker et at., found
mean PCB levels of 24.4 ppb in community members and 75.1 ppb in workers
occupationally exposed to PCBs.
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The long term consequences of PCB exposure to humans remain unknown. In
occupationally exposed groups, a skin eruption known as chloracne has been
the only medical finding consistently associated with PCB exposure. In the
accidentally exposed community in Japan--the famous Yusho incident--more than
l,000 members of the community ingested an estimated l-15 milligrams of PCBs
in contaminated rice oil daily for more than three months. Symptoms of the
resulting illness included chloracne, eye discharge, flattened nailbeds, and
hyperpigmentation. Babies born to women who ingested the oil were darkly
pigmented, had eye discharge, and jaundice (Kuratsune et al., 1972). In
animals, PCBs appear to be mutagenic, and are associated with increased fetal
loss, fatty degeneration of the liver and kidneys, and tumors of the liver
and pituitary gland (Kimbrough, 1974). Although such effect have not been
demonstrated in humans, animals studies serve to guide the standards of
acceptable human exposure.
3.4 REFERENCES
Cordle, J.J., R. Locke, and J. Springer. 1982. Risk Assessment in a Federal
Regulatory Agency: An Assessment of Risk Associated with the Human
Consumption of Some Species of Fish Contaminated with Polychlorinated
Biphenyls. Environmental Health Perspectives 45:171.
DHEW, PHS, CDC, NIOSH, 1977.
Occupational Exposure to
1977.
Criteria for a Recommended Standard:
Polychlorinated Biphenyls (PCBs). September
EPA, 1980. Ambient Water Quality Criteria for Polychlorinated Biphenyls.
EPA 440/5-80-068.
HTHCC, 1985. Handbook of Toxic & Hazardous Chemicals and Carcinogens, Noyes
Publications, New Jersey, pp. 737-739.
Hudson, B. D.,
Carolina.
p. 155.
1984. Soil Survey of Cumberland and Hoke Counties, North
U.S. Department of Agriculture, Soil conversation Service,
IACR, 1974 and 1978. International Agency for Research of Cancer, IACR
Monographs on the carcinogenic Risks of Chemicals to Humans, Lyon France,
7:261 (1974) and 18:43 (1978).
IACR, 1979. International Agency for Research of Cancer, IACR Monographs on
the Carcinogenic Risks of Chemicals to Humans, supplement 1, Lyon France,
p 41, 1979.
Kimbrough, R. D., 1974. The Toxicity of Polychlorinated Polycyclic Compounds
and Related Chemicals. CRC Critical Reviews in Toxicology, January 1974.
Kuratsune, M. et al, 1972. Epidemiologic Survey on Yusho, a Poisoning Caused
by Ingestion of Rice Oil Contaminated with a Commercial Brand of
Polychlorinated Biphenyls. Environmental Health Perspectives, April
1972, pp. 119-128.
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Schipf, R.G., 1961. Geology and Ground-Water Resources of the Fayetteville
Area. North Carolina Department of Water Resources, Ground-Water
Bulletin No. 3, p. 99.
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4.0 PRELIMINARY ASSESSMENT.OF REMEDIAL ALTERNATIVES
The purpose of conducting a preliminary assessment of remedial alternatives
early in the RI process is to identify alternative approaches for site
remediation, to establish criteria for evaluating the alternative approaches
under consideration, and finally, to determine the type and extent of data
needed to conceptualize, screen, ·and evaluate each of the alternatives based
on the overall technical approach proposed for the RI.
According to the most recent draft of the National Contingency Plan (NCP),
Section 300.68(f) Development of Alternatives, site-specific alternatives
addressing, at a minimum, the following five categories must be developed:
* Alternatives for off-site treatment and disposal;
• Alternatives that comply with all applicable and/or
relevant public health or environmental standards;
• Alternatives that exceed requirements of all
applicable and/or relevant public health or
environmental standards;
• Alternatives that do not attain applicable or relevant
public health or environmental standards but will
reduce the likelihood of present or future threat from
the hazardous substances or pollutants and
contaminants; and
• No action alternative.
The Superfund Amendments and Reauthorization Act (SARA) has modified the NCP
requirements to emphasize alternatives that reduce risk through destruction
or detoxification of hazardous wastes by employing treatment technologies
which reduce toxicity, mobility, or volume, rather than merely providing
protection through prevention of exposure. Another significant change
mandated by SARA is the incorporation of applicable or relevant and
appropriate requirements (ARARs) of other federal, state, and local
environmental rules and regulations in the implementation of remedial
actions.
Initial screening of the alternatives identified in each of the categories
listed above is performed based upon the following criteria: cost,
availability of acceptable engineering technology, and the accepted
effectiveness of each alternative. Thereafter, a detailed evaluation is
conducted for a limited number of alternatives. This evaluation leads to
identification of data requirements for the remedial investigation, and
subsequently, the development of specific objectives and a detailed approach
for the RI/FS.
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4.1 REMEDIAL ALTERNATIVES IDENTIFICATION
Table 4-1 presents a comprehensive list of methods commonly evaluated for
remediation of hazardous wastes at CERCLA sites. This information was
compiled from Section 300.70, Methods of Remedying Releases, as it appears in
the National Contingency Plan with a few additional methods included,
Remedies from this list that are applicable to the Carolina Transformer Site
will be identified and discussed in relation to the five categories of
remedial alternatives previously described, with emphasis being placed on
those alternatives that reduce toxicity, mobility, or volume as mandated by
SARA.
4.1.1 ALTERNATIVES FOR OFF-SITE TREATMENT OR DISPOSAL
A combination of off-site treatment and/or disposal could theoretically be
applied. Contaminated soils could be excavated and transported off-site for
disposal with or without treatment. Some of the contaminants in the soils
are amenable to chemical treatment or incineration. Chemical treatment of
wastes could be performed on-site prior to shipment off-site or at the
disposal facility. All of the wastes would have to be transported and
disposed of, or treated at, a RCRA-approved hazardous waste treatment
facility. This category is applicable only to remediation of contaminated
soils and is desirable over other alternatives which would merely contain
wastes on-site
4.1.2 ALTERNATIVES THAT COMPLY WITH ALL APPLICABLE AND/OR RELEVANT PUBLIC
HEALTH AND ENVIRONMENTAL STANDARDS
Collection and treatment of any contaminated ground water on-site or off-site
could theoretically be implemented in a manner to comply with federal
standards, Excavation of soils to background contaminant levels would be
required. Treatment.of the ground water to reduce the concentration of
contaminants to levels consistent with applicable state or local drinking
water criteria would also be required.
4.1.3 ALTERNATIVES THAT EXCEED REQUIREMENTS OF ALL APPLICABLE AND/OR
RELEVANT PUBLIC HEALTH OR ENVIRONMENTAL STANDARDS
The same alternatives described in Section 4.1.2 can be applied to this
category. However, in order to exceed the applicable standards, removal of
contaminants from ground water to levels below the standards would also be
required. Soils would be removed to levels below background.
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TABLE 4-1
POTENTIAL METHODS OF SITE REMEDIATION
CAROLINA TRANSFORMER COMPANY SITE
FAYETTEVILLE, CUMBERLAND COUNTY, NORTH CAROLINA
Engineering Methods for
On-site Actions
Air Emissions Control
Surface Water Controls
a. surface seals
b. surface water diversion
and collection systems
c. grading
d. revegetation
Groundwater Controls
a. impermeable barriers
b. permeable treatment beds
c. groundwater pumping/treatment
d. leachate control -collection
and treatment
Direct Waste Treatment Methods
a. biological treatment
b. chemical methods
c. physical methods
Decontamination of Soils/Sediments
a.
b.
c.
On-site
incineration
soil washing/flushing
neutralization/detoxification
Containment
a. RCRA facility
b. chemical fixation and replacement
c. in-situ chemical fixation
d. solidification
• NCP, Section 300.70, and others.
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Off-site Transportation for
Storage, Treatment, Destruction or
Secure Disposition Off-site
Excavation
Hydraulic Dredging
Provide Alternative Water Supply
Extend Existing Distribution
Provide New Wells
Provide Treatment to Remove
Contaminants from Existing
System
Relocation
Permanent Relocation of
Receptors
Temporary Relocation of
Receptors
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4.1.4 ALTERNATIVES THAT DO NOT ATTAIN APPLICABLE OR RELEVANT PUBLIC HEALTH
OR ENVIRONMENTAL STANDARDS, BUT WILL REDUCE THE LIKELIHOOD OF PRESENT
OR FUTURE THREAT FROM HAZARDOUS SUBSTANCES OR POLLUTANTS AND
CONTAMINANTS
There is a relatively limited number of possible remedial alternatives for
this site under this category. These include:
* In situ treatment or fixation of contaminated soils
to prevent further soil and/or ground water
contamination;
• Collection and treatment of the ground water to
background contaminant levels, followed by
reinjection of the treated ground water or discharge
to surface waters;
* Removal of soil "hot spots," but leaving others at
levels above background; and
* Closure of the site in accordance with RCRA
regulations, but leaving the groundwater untreated
or treated to levels above background.
4.1.5 NO ACTION ALTERNATIVE
Given the known site characteristics, such as levels of contamination and the
presence of sources of contamination, the no action alternative probably will
not be considered an acceptable alternative, but will be used as the basis
for the risk assessment.
4.2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS IARARs)
Superfund remedial activities under SARA must attain the applicable or
relevant and appropriate requirements (ARARs) of federal, state, or local
environmental statutes, whichever are more stringent. Federal standards may
include RCRA, Clear Air Act, Safe Drinking Water Act, Clean Water Act, Toxic
Substances Control Act, or Water Quality Criteria. State standards include
any promulgated by the State of North Carolina Department of Natural
Resources and Community Development or North Carolina Department of Human
Resources, and local statutes including those by Cumberland County.
Screening of the remedial alternatives will require an evaluation of each
alternative with regard to its ability to comply with the ARARs. The ARARs
are generally based on acceptable levels of contamination for the
preservation of the environment, -and the public health and welfare. ARARs
may also include consideration of technical and economic feasibility.
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The Agency will review all federal and state environmental laws that are
either "applicable" or "relevant and appropriate" for the Carolina
Transformer site. "Applicable" requirements are those standards, criteria or
limitations promulgated under federal or state law that specifically address
a hazardous substance, pollutant, contaminant, remedial action, location, or
other circumstance at a CERCLA site. "Relevant and appropriate" requirements
are those that while not "applicable" still address problems or situations
sufficiently similar to those encountered at the site that their use is well
suited to the particular site.
ARARs are identified on a site-specific basis and depend on these factors:
specific chemicals at a site, site characteristics, and particular actions as
a remedy.
The ARARs that apply to the site will be identified on a preliminary basis in
the scoping of the RI/FS. Once the RI/FS is underway and additional
site-specific information becomes available, ARARs will be more precisely
defined.
During the entire RI/FS and remedy selection processes, the identification of
ARARs will be reevaluated and redefined during at least the following stages:
Stage I During scoping of the RI/FS:
Chemical-specific and location-specific ARARs will be identified on a
preliminary basis.
Stage II During the site characterization phase of the Remedial
Investigation:
When the public health evaluation is conducted to assess risks at a
site, the chemical-specific ARARs and location-specific ARARs will be
identified more comprehensively and used to help determine the
cleanup goals.
Stage III During development of remedial alternatives in the Feasibility
Study:
Action-specific ARARs will be identified for each of the proposed
alternatives and considered along with other ARARs.
Stage IV During detailed analysis of alternatives in the Feasibility
Study:
All the ARARs for each alternative will be examined as a package to
determine what is needed to comply with other laws and be protective.
Stage V When an alternative is selected:
The remedy will attain all ARARs unless one of the six statutory
waivers is invoked.
Stage VI During remedial design:
The technical specifications of construction will ensure attainment
of ARARs.
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Each of the terms "applicable" and "relevant and appropriate" can be further
subdivided into three types: chemical-specific, location· specific, and
action-specific. Since ARARs can also be either federal or· state, there can
be as many as 12 different generic categories of ARARs that will be
considered for the site. These categories are:
(1) Federal -Applicable -Chemical-Specific
(2) Federal -Applicable -Location-Specific
(3) Federal -Applicable -Action-Specific
(4) Federal -Relevant and Appropriate -Chemical-Specific
(5) Federal -Relevant and Appropriate -Location-specific
(6) Federal -Relevant and Appropriate -Action-Specific
(7) North Carolina -Applicable -Chemical-Specific
(8) North Carolina -Applicable -Location-Specific
(9) North Carolina -Applicable -Action-Specific
(10) North Carolina -Relevant and Appropriate -Chemical-Specific
(11) North Carolina -Relevant and Appropriate -Location-Specific
(12) North Carolina -Relevant and Appropriate -Action-Specific
Chemical-specific requirements are health or risk-based concentration limits
or ranges in various environmental media for specific substances, pollutants
or contaminants.
Location specific requirements are restrictions on activities depending on
the characteristics of the site and its immediate environment.
Action-specific requirements are controls or restrictions on particular kinds
of activities related to the particular remedial activity selected to manage
the hazardous substances, pollutants, or contaminants.
STAGE I -Preliminary Identification of ARARs
Based on this initial information, the potential ARARs to be considered for
this site during the scoping of the RI/FS process are:
4.2.l FEDERAL ARARS
l. Federal -Applicable -Chemical-Specific
(a) The Toxic Substance Control Act (TSCA), codified at 15
u.s.c. S 2601 et seq. regulates the manufacturing, processing,
distribution, use and disposal of Polychlorinated Biphenyls
(PCBs) in S 6(e) (15 u.s.c. S 260S(e)). comprehensive EPA
regulations controlling PCBs are found in 40 C.F.R. Part 761.
The Chemical-Specific regulatory level for PCBs is specified in
40 C.F.R. S 761.l as 50 parts per million (ppm) and above. The
provisions of 40 C.F.R. Part 761 are applicable to the disposal
and storage of PCBs in concentrations of 50 parts per million and
above.
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(b) 40 C.F.R. S 129.105(a) (4) specifies that the ambient water
criteria for PCBs in navigable waters is 0.001 micrograms per
liter.
{c) RCRA rules (40 CFR Part 264) covering ground water
monitoring will be included.
(d) The maximum contaminant levels (MCLs) as specified in 40 CFR
Part 141.61 will be included.
2. Federal -Applicable -Location-Specific
(a) 40 C.F.R. S 761.65(b) (v) provides that any facility used
for the storage of PCBs and PCB items must not be located at a
site that is below the 100-year flood water elevation.
(b) 40 C.F.R. S 761.75(b) provides that chemical waste landfills
used for the disposal of PCBe and PCB items meet specified
requirements for soil, hydrologic conditions, flood protection
and topography.
3. Federal -Applicable -Action-Specific
No requirements can be identified until proposed remedial
alternatives have been identified for the site.
4. Federal -Relevant and Appropriate -Chemical-Specific
(a) Section 307 of the Clean Water Act, 33 u.s.c. S 1317
authorizes EPA to established effluent limitations for the
discharge of toxic pollutants into navigable waters. 40 C.F.R. S
129.105 establishes an effluent standard for the discharge of
· PCBs from PCB manufacturers and from manufacturers of electrical
capacitors and electrical transformers. The standard is a
prohibition on the discharge on any PCB with an adjustment
available for the presence of PCBs in intake water.
(b) The EPA's Office of Health and Environmental Assessment
(OHEA) has calculated that the human dose associated with a 1 x
10-6 level of oncogenic risk for PCB in soils is 0.0175
micrograms/day (52 Fed. Reg. 10696, April 2, 1987).
(c) ·40 C.F.R. S 761.125(c) (3) establishes requirements for
decontaminating by spills of PCBs in restricted access areas.
Soils contaminated by spills of PCBs must be cleaned to 25 ppm
PCBs by weight.
{d) 40 C.F.R. S 761.125(c) (4) establishes requirements for
decontaminating spills of PCBs in non-restricted access areas.
Soils contaminated by spills must be decontaminated to 10 ppm
PCBs by weight provided that soil is excavated to a minimum depth
of 10 inches.
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(e) 40 C.F.R. S 761.3 provides that the release of inadvertently
generated PCBa at the point at which emissions are vented to
ambient air must be leas than 10 ppm.
(f) 40 C.F.R. S 761.3 provides the amount of inadvertently
generated PCBs added to water discharged from a manufacturing
site must be less than 100 micrograms per resolvable gas
chromatographic peak per liter of water discharged.
5. Federal Relevant and Appropriate -Location-Specific
The disposal of PCBs is not specifically regulated by the
Resource Conservation and Recovery Act (RCRA), codified at 42
u.s.c. S 6901 et seq. RCRA, however, does contain location
standards for hazardous waste treatment. storage, and disposal
facilities. Those standards are generally found at 40 C.F.R. S
265.18 and 264.18.
6. Federal -Relevant· and Appropriate -Action-Specific
No requirements can be identified until proposed remedial
alternatives have been identified for the site.
4.2.2 STATE ARARS
7. North Carolina -Applicable Chemical-Specific
(a) The North Carolina Code, Title 15, Department of Natural
Resources and Community Development, Environmental Management
Division, Subchapter 2L, Classifications and Water Quality
Standards Applicable to the Groundwaters of North Carolina,
sections .0100, .0200 and .0300 (15 NCAC 2L) was identified by
the State as an ARAR.
(b) Title 15 North Carolina Administrative Code (NCAC)
Subchapter 2B of the State of North Carolina Department of
Natural Resources & Community 0evelopment Division of
Environmental Management defines surface water quality
classifications and standards. Surface waters of North Carolina
have been classified according to designated uses as follows:
(c) Freshwater Classifications
• Class WS-I.: Waters protected as water supplies which are in
natural and uninhabited or predominantly undeveloped
(not urbanized) watersheds. No point source discharges
are permitted and local land management programs to
contr9l nonpoint source pollution are required.
Suitable for all Class C uses.
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• Class WS-II: Water protected as water supplies which are in
low to moderately developed (urbanized) watershed.
Discharges are restricted to primarily domestic
wastewater or industrial non-process waters specifically
approved by the commission. Local land management
programs to coritrol nonpoint source pollution are
required. Suitable for all Class C uses.
• Class WS-III: Water supply segment with no categorical
restrictions on watershed development or discharges.
Suitable for all Class C uses.
• Class B: Suitable for swimming, primary recreation and all
Class C uses.
• Class C: Suitable for secondary recreation and fish
propagation.
(d) Tidal Salt Water Classifications
• Class SA: Suitable for commercial shell-fishing and all
other tidal salt water uses.
• Class SB: Suitable for swimming and primary recreation and
all Class SC uses.
• Claes SC: Suitable for secondary recreation and fish
propagation.
(e) Supplemental Classifications
• Trout Waters: Suitable for natural trout propagation and
maintenance of stocked trout.
• Swamp Waters: Waters which have low velocities and other
natural characteristics which are different from
adjacent streams.
• Nutrient sensitive Waters: Waters requiring limitations on
nutrient inputs.
• 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.
.surface waters close to the Carolina Transformer Site fall into Class c and
Class WS II as determined in defined Subchapter 2B 0.0200 of NCAC Title 15
defines classifications and water quality standards applicable to surface
waters of North Carolina.
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(f) Groundwater Standards Defining acceptable contamination
levels will be based on the State Ground Water Criteria and
Federal Guidelines where available, in conjunction with public
health evaluations and risk assessments performed by toxicology
experts. Subchapter 2L of NCAC Title 15 defines classifications
and ground wate~ quality standards applicable to ground waters of
North Carolina. The ground water classifications defined by
Subchapter 2L are as follows:
* Class GA Waters-Usage and occurrence
Best Usage of Waters: Existing or potential source of
water supply for drinking, culinary use, and food
processing ~ithout treatment, except where necessary to
correct naturally occurring conditions.
Conditions Related to Best Usage: This class is
intended for those ground waters in which chloride
concentrations are equal to or less than 250 mg/L,
considered safe for drinking, culinary use, and food
processing without treatment, but which may require
disinfection or other treatment when necessary to reduce
naturally occurring concentrations in order not to
exceed the maximum concentrations specified in Title 15
NCAC 2L 0202.
occurrence: At depths greater than 20 feet below land
surface and in the saturated zone above a depth of 20
feet where these waters are a principal source of
potable water supply.
• Class GSA Waters-Usage and occurrence
Best Usage: Existing or potential source of water
supply for potable mineral water, culinary use, food
processing, and conversion to fresh waters by treatment.
Conditions Related to Best Usage: This class is
intended for those ground waters in which naturally
-occurring chloride concentrations are greater than 250
mg/L, and which are considered safe for potable mineral
water, culinary use, and food processing without
treatment but may require disinfection or other
treatment when necessary to reduce naturally occurring
concentrations in order not to exceed the maximum
concentrations specified in Title 15 NCAC 2L 0202.
Occurrence: At depths greater than 20 feet below land
surface and in the saturated zone above a depth of 20
feet where these waters are a principal source of
potable mineral water supply.
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* Clase GB Waters-Usage and Occurrence
Best Usage: Source of recharge to surface waters and
ground waters occurring below a depth of 20 feet.
Source of treatable water supply.
Conditions Related to Best Usage: Precipitation is the
principal source of recharge to the saturated zone.
Water in the saturated zone above a depth of 20 feet is
of drinking water quality in much of the state.
However, the upper 20 feet of the earth's surface is
generally very vulnerable to pollution from man's
activities, and should be considered a cycling zone for
removing most or all of the contaminants from the water by adsorption/filtration or other natural treatment
processes. In recognition of this fact, this
classification is intended for those fresh ground waters
occurring at depths of less than 20 feet below land
surface that are of suitable quality for recharge to the
deeper aquifers and surface waters of the state,
Occurrence: Above a depth of 20 feet below land
surface.
• Class GSB Waters-Usage and Occurrence
Best Usage: Source of recharge to saline surface waters and saline ground waters occurring below a depth of 20 feet. Source of treatable water supply.
Conditions Related to Best Usage: Precipitation is the
principal source of recharge to the saturated zone. The
water in the saturated zone above a depth of 20 feet of
the earth's surface is generally very vulnerable to
pollution from man"s activities and should be considered
a cycling zone for removing most or all of the
contaminants from the water by adsorption, absorption,
filtration or other natural treatment processes. In
recognition of this fact, this classification is
intended for those saline ground waters occurring at
depths less than 20 feet below land surface that are of suitable quality for recharge to the deeper aquifers and
surface waters of the state.
Occurrence: Above a depth of 20 feet below land
surface.
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* Class GC Waters -Usage and Occurrence
Best Usage Waters: Source of water supply for purposes
other than human drinking, culinary use, or food
processing.
Conditions Related to Best Usage: This class includes
those waters that do not meet the quality criteria
requirements of waters having a higher classification
and for which measures to upgrade to a higher
classification would technically or economically not be
feasible, or not in the beet interest of tpe public, or
for which maximum feasible restoration has been
completed.
Occurrence: As determined by the commission on a case
by case basis.
Comparing North Carolina's groundwater classifications to information
currently available on the site indicates that groundwater in the shallow
aquifer at the Carolina Transformer Site falls into the Class 2A category.
Groundwater in the middle aquifer is classified as 2A and the water found in
the deepest aquifer would also be classified as Class 2A. Remedial
alternatives must be evaluated with regard to their ability to create
conditions that meet or exceed these state groundwater standards or criteria,
as related to background groundwater characteristics at the sitee
(g) Hazardous Waste Regulations: Title 10 NCAC Subchapter F
defines standards, criteria, and permitting requirements for
hazardous waste facilities within the State of North Carolina.
10 NCAC Subchapter Fis substantially identical to federal
regulations in 40 CFR parts 262, 263, 264, and 265.
8. North Carolina -Applicable -Location-Specific
No requirements more stringent than the federal requirements have
been identified.
9. North Carolina -Applicable Action-Specific
No requirements more stringent than the federal requirements have
been identified.
10. North Carolina -Relevant and Appropriate -Chemical-Specific
No requirements more stringent than the federal requirements have
been identified.
11. North Carolina -Relevant and Appropriate -Location-Specific
No requirements more stringent than the federal requirements have
been identified.
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4.2.3 LOCAL STANDARDS AND CRITERIA
Local groundwater and surface water criteria/standards and hazardous waste
regulations are presently unidentified, but will be determined during the
remedial investigation.
4.3 APPROACH TO EVALUATION OF ALTERNATIVES
Three factors will be used ·as the basis for evaluating remedial alternatives
during the FS Phase. The factors include ability to implement,
effectiveness, and cost. Using these factors will provide a consistent basis
for comparison of remedial alternatives.
Specific items which may be used for evaluating each of three factors are
listed below:
1. Implementability
Ability to Implement -This factor will be evaluated based on the
following items:
Technology -Has the technology been successfully applied in a
similar remedial action project on a full-scale basis?
Reliability -Is the technology dependable; can equipment be expected
to operate with a minimum of downtime?
Operability -Is the technology simple to operate; can it be
practically operated under the site field conditions?
Flexibility -Will the technology operate efficiently under variable
conditions (i.e., safety constraints required by nature of the
contaminated soils or varying hydraulic loadings for a ground
water treatment system)?
Equipment availability -Is the equipment commercially and readily
available for field application or can a long delivery time be
expected?
Susceptibility to toxic contaminants -Is the technology subject to
upset due to the presence of toxic constituents (i.e., soil and
ground water treatment process}?
Acceptability Have federal and/or state regulatory agencies
accepted the technology at other sites?
Safety -Can full-scale equipment be safely operated? What
precautions are necessary?
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Permits -Are permits or licenses necessary for construction,
operation, effluent discharges and can permits be obtained in a
timeframe consistent with this project?
2. Effectiveness
3.
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The purpose of remedial action at the site is to correct existing and
potential future environmental effects and mitigate conditions tha~
could potentially affect public health in the area. Therefore, the
ability of a remedial alternative to mitigate/eliminate these impacts
is important. The effectiveness of the remedial alternatives will be
evaluated based on the following items:
Does the alternative prevent human access or possible contact with the
contaminated materials after site work is completed?
Does the alternatives reduce existing and potential future ground water
contamination?
How will implementation of the alternative impact other media (air,
land, surface water, and ground water) during and after remedial
action?
Will the alternative minimize potential adverse impacts on human
health, wildlife and vegetation, neighboring properties, and other
sensitive populations?
Will the alternative attain or exceed the ARARs?
Will the alternative significantly and permanently reduce the toxicity,
mobility or volume of the waste?
Is the alternative technically reliable?
To what extent will the alternative abate/minimize existing and
potential future migration and contamination of air, soils, and surface
waters?
Cost
A remedial cleanup program must not only be effective for meeting the
environmental objectives of the remedial action, but must also be
implemented in a cost-effective manner. In evaluating the cost factor
of various remedial alternatives, costs for each alternative will be
identified by taking into consideration capital costs, labor/expenses,
operating costs, and any long-term maintenance costs. A present worth
method, approved by the EPA, will be utilized for cost comparison
purposes. Cost is important when comparing alternatives which provide
similar results, but will not be used to compare treatment and
non-treatment alternatives.
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4,4 IDENTIFICATION OF DATA REQUIREMENTS
In order to screen and evaluate the preliminary list of remedial
alternatives, additional site-specific data on the types and extent of
contamination, and the pathways for contaminant migration, must be
collected. Based on information in the existing database, the following list
of specific data requirements for the Carolina Transformer Site was
developed:
• A hydrogeologic investigation focusing on site-specific
groundwater flow characteristics must be conducted to evaluate
possible contaminant pathways and the potential for further
off-site contamination. Several reports on the regional
hydrogeologic conditions are available but site-specific
information on both the upper and lower aquifers is
inadequate. An aquifer test and soil permeability testing are
needed to evaluate the hydrogeologic properties of the aquifer
systems. Simultaneous groundwater level measurements are also
needed to qetermine groundwater flow directions and
velocities. These data are required to evaluate the
applicability of leachate or groundwater collection and
treatment technologies and the potential effectiveness of
source control measu~es. These data are also needed to
evaluate future risk to public health and the environment.
• A groundwater quality investigation must be conducted to
determine the horizontal and vertical extent of groundwater
contamination. Available groundwater quality data indicate
that contamination has reached a local water supply well,
However, the areal extent of groundwater contamination has not
been well defined. In addition, the vertical extent of
contamination has not been established. The types and
concentration levels of contaminants must also be better
defined. Background groundwater quality data must also be
collected to form a baseline for evaluating the extent of
groundwater contamination emanating from the site. All these
data are needed to evaluate alternative groundwater
collection, treatment, and disposal options as well as the
risk to public health and the environment if the no action
alternative is selected,
• A surface soil investigation is required to determine the
horizontal and vertical extent of contaminated soils and the
potential for off-site migration. Soil samples have been
collected and analyzed for contamination, but more are needed
to evaluate the contaminant source control alternatives. In
addition, the grain size distribution for surface soil and
percent organic carbon must be determined to allow transport
and fate analysis.
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* A surface water/sediment investigation must be conducted to
evaluate the extent of surface water contamination and the
potential for further off-site migration. Several surface
water/sediment analyses have been performed in previous
investigations. These analyses have indicated that
contamination from the site has migrated into several of the
drainage ways on and around the site. The present extent of
the surface water contamination, however, is unknown and needs
to be defined. In addition, the possible migration of
contaminants off-site needs to be evaluated. Background
surface water quality data must also be collected to form a
baseline for evaluating the extent of surface water
contamination emanating from the site. All these data are
needed to evaluate alternative surface water collection,
treatment, and disposal options as well as the risk to public
health and the environment if the no action alternative is
selected.
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5.0 SCOPE OF WORK FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY
5.1 OBJECTIVES OF THE REMEDIAL INVESTIGATION/FEASIBLITY STUDY
This section of the Work Plan for the Carolina Transformer site describes the
specific work to be conducted with regards to the site.
Several deficiencies have been identified in the existing data base for the
Carolina Transformer site that prevents the immediate development of a
cost-effective remedial action plan. The primary objective of the RI is to
collect an adequate amount of data to eliminate these deficiencies, which are
described in Section 1.0. The objective of the FS is to evaluate the data in
such a manner as to provide a basis on which to support a recommended
remedial action.
5.1.1 OBJECTIVES
The objective of the RI/FS is to expand the existing data base and provide
new data from areas that were not investigated previously by EPA. This data
will be used to 1) document the cleanup conducted previously by EPA, 2)
document the nature and extent of contamination, 3) develop and recommend a
cost effective remedial action, as required under CERCLA and SARA.
Specific objectives of the RI include:
• Determining the areal and vertical extent-of potential contamination in
the soil, surface water, sediments, ground water, and tanks, drums and
buildings.
• Determining the geologic and hydraulic characteristics of the aquifer
system, including flow directions and velocities of the ground water
flow.
• Determining transport mechanisms and contaminants fates.
• To assess public health risks and environmental impacts associated with
contaminants.
• To identify technological options for cleaning up contaminants onsite
and preventing·migration of contaminants offsite.
• To evaluate remedial alternatives consistent with the National
Contingency Plan (NCP) and other regulatory requirements and guidelines.
• To select a remedial action that is technically and environmentally
sound and cost effective.
• Documenting the effectiveness of the emergency cleanup performed by EPA .
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5.2 REMEDIAL INVESTIGATION/FEASIBILITY STUDY TASKS
5.2.1 PROJECT PLANNING
The project planning task includes all work efforts related to initiating the
RI/FS after the work assignment is issued.
5.2.1.1 Work Plan Memorandum
Since the work is being performed by the Agency with assistant from sister
Agencies, where deemed necessary, a Work Plan Memorandum is not needed for
this work plan.
5.2.1.2 Site Visit
Site visits were made on May 25, 1988 and August 31, 1988 to assess the
current statue of the site. The visits were made by Jon Bornholm of EPA,
Flint Worrell of the North Carolina Department of Human Services, otis
Kitchen of William Russell & Johnson, Jim Susan of CCJM, Richard Muza of
Ground-Water Technology Unit, and Michael Henderson, Office of Congressional
and External Affairs. During the site visit, the property and surrounding
areas were toured and the scope of the RI/FS was discussed.
5.2.1.3 Review of Existing Data
Prior to the development of the Work Plan, the existing data located in EPA's
file were reviewed and evaluated. Additional data were obtained from the
United States Geological Survey (USGS) and the State of North Carolina.
These data were used to provide a preliminary assessment of the nature and
extent of contamination and of possible remedial alternatives. Additional
data needed to evaluate the potential impacts on public health, welfare, and
the environment and to perform a feasibility study consistent with
requirements of SARA and the NCP were also identified.
5.2.1.4 Identify ARARs
All Applicable, Relevant, and Appropriate Requirements (ARARs) or standards
were identified for the contaminants known to be present.at the site. All
federal, state, and local standards or criteria for public health and for the
environment are reviewed. Results of this subtask are presented in Section
4.2 of this document.
5.2.1.5 Identify Preliminary Remedial Alternatives
This subtask was used to identify preliminary remedial technologies to ensure
that the field investigation will develop a data base adequate for the
evaluation of alternatives during the feasibility study. Results from this
subtask are presented in Section 4.1 of this RI/FS Work Plan.
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5.2.1.6 Work Plan Preparation
The Work Plan defines the scope of work, level of effort, costs, and schedule
associated with performing the RI/FS. The prime responsibility for the
preparation and execution of the Work Plan will be with EPA.
The work plan includes detailed descriptions of each task to be performed.
Tasks and subtasks are selected a~d organized based on the RI/FS guidance.
The four (4) main components of the work plan are described below.
Initial Site Evaluation
The first part of the work plan includes a review and evaluation of all
available site information. Information collected in scoping meetings,
during the site visit, and from the existing data base is organized and
summarized in a logical format.
Contamination Problem Definition
This portion of the work plan includes an analysis of the concentration,
toxicity, and characteristics of waste contaminants disposed of at the
site. Also included is an initial evaluation of the migration pathways,
potential receptors, and environmental and public health concerns.
Preliminary Assessment of Remedial Alternatives
This section of the work plan includes the identification of alternative
remedial approaches for cleaning up the site, and the criteria for
evaluating those approaches. It also includes an assessment of the data
gaps.
Scope of Work for Remedial Investigation/Feasibility Study
This section of the work plan includes the development of appropriate
surveying and sampling activities to be performed in accordance with EPA
standards and guidelines to fill the identified data gaps. This section
also includes a description of project planning tasks, community relations,
sample analysis and validation, data evaluation, risk assessment,
treatability studies, RI report preparation, remedial alternatives
screening and evaluation, FS report preparation, post-RI/FS report
preparation, enforcement support, miscellaneous EPA activities support, and
expedited response actions.
A draft work plan is first developed using the information collected at the
scoping meeting, site visit, and from the existing data base. After
appropriate review, a final work plan will be developed incorporating fitting
comments received during the review.
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5.2.1.7 Quality Assurance Project Plan Preparation
All technical aspects of the Carolina Transformer site RI/FS and personnel
engaged in the execution of this project are subject to EPA Region IV quality
assurance programs. The quality assurance Project Plan (QAPP) specifies the
procedures which must be implemented to assure that all aspects of the RI/FS
are consistent with the specific quality goals of these programs. The
activities and products addressed in the QAPP include:
• Technical deliverables
• Graphics
• Analytical procedures and data validation
• Sampling procedures
• Calibration of field and laboratory instruments
• Sample custody
* Data reduction and processing
• Field methods
• Laboratory methods
• Internal quality control checks
• Performance and system audits
* Preventive maintenance
* Corrective action
5.2.1.B Project Operations Plan Preparation
The Project Operations Plan (POP) identifies the individuals responsible and
detailed procedures for conducting all field activities supporting the
RI/FS. The POP serves as the major quality control document for the field
activities undertaken at the site, but is subject to modification, as
necessary, throughout the investigation to accommodate contingencies. The
four (5) main components of the POP are health and safety, sampling and
analysis, data quality objectives, site management and data management.
Health and Safety
This portion of the POP presents the health and safety requirements for
each task and/or phase of the RI/Fs. It identifies individuals responsible
for monitoring all field activities in compliance with the established
health and safety procedures, describes detailed personnel monitoring and
decontamination procedures, and also addresses health and safety training
procedures and requirements for all onsite personnel, including
representatives from other Agencie~ or subcontractors.
Sampling and Analysis
This portion of the POP presents detailed descriptions of the sampling
locations, methodologies, equipment requirements, decontamination
procedures, sample codes, sample handling/shipping procedures
(chain-of-custody), mobilization activities, and identifies the anticipated
field team for each task. Also, the POP presents details of sample
preparation/preservation, sample bottle requirements and identifies the
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analytical methods to be followed for analysis of samples. In all cases, sampling and analyses will be performed as set forth in the EPA Region IV ESD SOPs.
Data quality Objectives
Data Quality Objectives (DQO's) are applicable to all tasks proposed for the field investigation. Table 5-l presents the data quality objective levels for environmental samples to be collected during various activities at the Carolina Transformer site. A more detailed listing is included in the POP.
Site Management
This section of the POP describes the chain-of-command and management procedures for field investigation coordination. Several tasks will be concurrently executed with close supervision coordination to ensure effective use of field crew(s). Communication network will be established between the onsite coordinator, office personnel, the EPA SPM, and other appropriate individuals and/or agencies. Furthermore, a contingency plan will be established to include trouble shooting procedures.
Data Management
The data management plan (DMP) will provide the procedures to be implemented to ensure reproducibility of all field activities. A description of how field logbooks provide documentation of all field activities and measurements is included. In addition, the DMP describes data management procedures for laboratory and subcontractor information. Furthermore, the •DMP describes procedures for security and document control. Standardized EPA procedures form the basis of the DMP. The DMP is included as part of the POP.
5.2.l.9 Data Quality Objectives
Remedial investigation and site characterization activities include data gathering and analysis so that the nature and extent of the constituent of concern can be evaluated. The data must be of sufficient quantity and quality to allow subsequent activities (i.e., remedial alternat.ive development, public health evaluations) to be carried out.in a satisfactory manner. Data quality objectives (DQOs) are established to properly focus data acquisition to meet the broad objectives of the CERCLA process. The DQOs are initially based on available knowledge of the site and preliminary assessments of what remediation may be required. The initial DQOs are revised as data is collected and various DQO elements are eliminated, e.g., after the first round of sampling of ground water, the list of analytical parameters for future sampling may be reduced to those parameters detected. Additionally results of sampling may show that future sampling of a particular medium such as surface water or stream sediment is not necessary. These revised DQOs allow for a cost-effective remedial alternative protective of human health and the environment. DQOs will not be revised without the approval of the Superfund Project Manager.
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Media
Air
Soil
Surface Water
Sediment
Groundwater
Drums, TankB,
and Buildings
TABLE 5-1
Data Quality Objectives
Carolina Transformer Site
Fayetteville, North Carolina
DQO Level Analysis
I
II
IV
II
IV
II
IV
II
IV
IV
HNu screening
voe screening using portable GC;
TCL organics and inorganics, plus
pesticides and PCBs
voe screening using portable GC;
TCL organics and inorganics, plus
pesticides and PCBs
voe screening using portable GC;
TCL organics and inorganics, plus
pesticides and PCBs
voe screening using portable GC;
TCL organics and inorganics, plus
pesticides and PCBs
TCL organics and inorganics, plus
pesticides and PCBs
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General considerations in developing DQOs include:
* Site characteristics
* Waste constituent characteristics
• ARARs
* Future data use such as nature and extent, potential pathways and
receptors, and remedial alternatives.
The DQOs are met by designing and implementing site-specific sampling plans
that are tailored to the site. The factors considered in the design of plans
include:
* media to be sampled
* number, location, and frequency of samples
* constituents to be analyzed.
The initial DQOs will identify indicator parameters for the various media,
when possible, based on previous site investigations, results of full TCL
scans, and knowledge of the environmental fate of likely waste constituents.
Selection of indicators will consider:
* the likely presence and concentration of constituents
• media-specific mobility
• toxicity.
The DQOs must also address the uncertainties involved in the site
investigation. For example, the initial round of sampling to determine the
extent of soil contamination (Phase I).will generate large amounts of data,
some areas may need additional definition. That further definition would
occur in a second round of sampling (Phase II). At the completion of the
Phase I RI the original DQOs are evaluated with regard to:
• quality control
• implications to definition of nature and extent implications to
potential remedial alternatives implications to public health or
environmental assessments.
The second Phase of the RI, if needed, will address the needs (data gaps)
defined by Phase I. Phase I DQOs are described below.
The information needed for the Phase I RI is as follows:
• The following is needed concerning geology at the Carolina Transformer
site:
Stratigraphy determined by subsurface samples.
Characterization of geotechnical, hydrological, and geological
parameters of the soils and bedrock if encountered.
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•
•
•
•
Confirmation of the given geological data including well logs and
hydrogeologic data such as hydraulic conductivities and
transmissivities
Definition of groundwater flow system.
Characterization of the chemical and physical properties of the
waste as it exists now at each site.
Evaluation of the extent of migration of the constituents of concern
from each site.
Evaluation of potential impacts to receptors .
Evaluation of treatment effectiveness of potential remedial
alternatives.
The following list summarizes Data Quality Objectives for the Phase I RI by
several categories of analysis or evaluation to be conducted.
Geology/Hydrogeology
• Stratigraphy (horizontal and vertical variability)
•
borings in saprolite (and bedrock if encountered) in conjunction
with soil sampling and well installation as described in Section
4 of the Work Plan,
identify potential migration pathways in the immediate vicinity
of site.
Soil types and physical properties
Grain size analysis
Atterberg limits
Hydraulic conductivity.
field values for horizontal according to procedures
described in Section 6,6 of the SOP
lab values for vertical
Geochemical properties (organic matter content)
Geophysical Measurements
• Traverse areas of suspected waste deposition with an Geonics EM-31
terrain conductivity meter set to detect magnetic fields.
• Traverse area of suspected waste deposition with a Schonstedt
magnetometer.
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Ground Water Flow and Quality
• Groundwater flow systems, both horizontal and vertical
*
*
*
determination of velocity and gradient distributions. Velocity
will be determined using measured gradients and permeabilities
and estimated porosity.
determine elevation of water levels to nearest 0.01 foot
according to procedures described in section 6.5 of the SOP.
evaluation of off-site "regional" flow system effects based on
local experience and regional data.
nature and extent of constituents of concern in the groundwater
delineating the extent will be by focusing on voes and the other
soluble constituents and PCBs
the nature of potential hazardous constituents will be determined
by select samples for the TCL parameters
rate of migration of the constituents of concern
current ground water users in potentially impacted areas (especially
between the site and the first downgradient ground water discharge
area). The percent of ground·water being discharged at the first
ground water discharge point will be estimated.
Soil and Waste
*
*
*
*
general nature and extent of wastes at sites (partially completed)
inspection of areas surrounding sites
geophysical surveys to delineate potential fill or waste disposal
areas
physical properties of waste for treatability evaluations including
water content, particle size and ash content
analyze the cation exchange and percent organic carbon for one soil
sample per site or area
nature and extent of constituents of concern in soil and waste
delineation of extent will focus on PCBa as a primary indicator.
Of particular interest is defining background conditions and
delineating areas having greater than 50 ppm of PCB. Part 761 of
40 CFR indicates that PCB concentrations leas than 50 ppm are not
regulated. All analytical results for all parameters will be
reported to EPA.
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area extent resulting from surface water runoff and scattering of waste will rely on surface (0-12") samples
areal distribution of waste will be delineated by visual
observations, geophysics and soil borings (five feet deep with
soil samples collected for visual classification only) located adjacent to the geophysical or visual anomaly. At sites where
there are no visible or geophysical anomalies present soil and
waste sample borings will be used.
vertical distribution will be delineated by borings
the nature of the constituents of concern in soil will be evaluated by analyzing select samples of soil for TCL parameters. One soil sample will be collected at 3.5 to 5 feet below the bottom of the waste in the soil/waste boring located
closest to the center of the suspected area of waste deposition. This sample location will have the greatest probability of detecting TCL constituents, if any, that have migrated from the waste into ·the soil. Only one soil sample will be collected from below the waste at each site for TCL analysis.
the nature of the constituents of concern in the waste will be evaluated by compositing samples of waste for the TCL parameter analyses (except for the voe fraction where individual samples will be analyzed).
Surface Water/Sediments
•
•
*
nature and extent of constituents of concern in nearby surface water and sediments
delineation of extent will focus on PCBs in sediments as a primary indicator
the nature of hazardous constituents in surface water and sediments will be evaluated by analyzing samples of sediment and surface water for those parameters detected in the TCL analyses of soils and waste
identification of potential human receptors
determine surface water elevations there appropriate) to the nearest 0.01.foot using a staff gage
Air Quality
* Identification of voes by making field measurements using an OVA and/or HNu and if necessary with sample tubes with charcoal or silica gel media prior to start of site work to define Health and safety criteria
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•
•
Identification of PCBa and particulates by collecting three air
samples from each site prior to start of RI activities
Identification of tetrachloroethylene and trichloroethylene using
detector tubes. One set of tube samples per waste boring
Laboratory
• contract lab program procedures for sample handling, analysis and
reporting
•
•
•
•
establishment of priorities for samples intended for TCL analysis
in the event of insufficient sample volume, l -PCBa; 2-voes; 3
balance of TCL parameters
specific QC requirements (e.g. accuracy, precision, completeness)
are defined in the Quality Assurance Project Plan
All analyses for organic compounds will be performed using the
Contract Laboratory Program (CLP) Statement of Work dated l/1987.
Inorganic analysis will be done by the CLP Statement of Work
dated 7/1985. The non-TCL analyses will be performed under the
US EPA method found in "Teat Method for Chemical Analysis of
Water and Waste" dated April 1979 with updates in 1982 and 1984.
Surveying
•
•
•
locate sampling and reference points horizontally according to
the South Carolina State plane coordinate system
locate sampling and reference points on a scaled topographic base
map for each site
determine elevations of measuring points and land surface for
monitoring wells and elevations of known reference on staff
gages. Elevations will be relative to mean sea level according
to the National Geodetic Vertical Datum of 1929.
5.2.1.10 Technical/Financial Management
This subtask includes preparing monthly technical and financial progress
reports, as needed, attending progress meetings, and implementing document
and project schedule control procedures for all activities and
deliverables associated with the project planning task. This same subtask
will also be performed in all subsequent tasks.
Monthly Reports and Progress Meetings
Monthly reports and progress meetings (as required) will cover (but are
not limited to) the following topics:
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* Work Assignment technical and financial status
• Project task status
• Anticipated problem areas
* Resolved problems
* Deliverables submitted
* Subcontracting
* Travel
• Personnel changes
* Schedule changes
• Meetings attended
Document and Project Schedule Controls
All documents pertaining to this RI/FS will be controlled in accordance
with to EPA procedures, All RI/FS activities will be tracked to assure
that all activities are completed and all deliverables are submitted in
accordance with the project schedules.
5.2.1.11 Quality Assurance/Quality Control
Quality assurance (QA) audits are a key mechanism for ensuring the
technical and procedural accuracy of hazardous waste management work
efforts. Two types of QA audits have been identified:
•
•
System Audit -This audit will entail checking the project files
to ensure that all the required document sign-offs have been made
indicating the required project quality control (QC) activities
have been performed.
Performance Audit -This audit is conducted by an audit team that
goes to the field (or office) and actually observes that proper
QC measures are being performed.
Quality assurance procedures for scheduling, implementing, and conducting
QA audits will be performed in accordance with the Quality Assurance
Program Plan.
All work will be reviewed in accordance with quality control objectives to
assure that technical performance and quality of deliverables meet
established standards, and that deficiencies are corrected. Detailed
quality control procedures are outlined in the Quality Assurance Program
Plan.
5.2.2 COMMUNITY RELATIONS
The community relations task includes all work efforts related to the
preparation of the community relations plan for the site. Thie task
includes time expended by both technical and community relations personnel
for community relations activities.
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5.2.2.1 Community Relations Plan
EPA will prepare and then initiate the Community Relations Plan. The CR plan
will describe community concerns regarding the site and outline a program of
community relations activities that will help EPA meet the concerns of the
community. It will include sections on site background, community
background, history of community involvement, key community concerns,
objectives of the community relations program, suggested community relations
activities and a proposed schedule for those activities, and possible
locations for public meetings and information repositories.
All work on the CR plan will be coordinated with EPA's Region IV Superfund
Community Relations Coordinator. In addition, all work under this section
will be prepared and conducted in compliance with Superfund Community
Relations Policy and Community Relations in Superfund: A Handbook (Interim
Version, September, 1983),
Potential activities that may be conducted as part of this task includes
directing public meetirigs, preparation of fact sheets or preparation of
meeting summaries.
5,2.2,2 Technical/Financial Management
Refer to Section 5.2.1.10
5.2.2.3 Quality Assurance/Quality Control
Refer to Section 5.2.1.11
5.2.3 FIELD INVESTIGATION
The field investigation task includes all field work efforts related to the
preparation of the RI. This task may include implementing interagency
agreements or the procurement of subcontractors to perform part of the field
work.
The proposed field investigation will consist of the following subtasks:
* Mobilization and Demobilization
* Implementing Interagency Agreements/Subcontractor Procurement
• Site Survey
* Geophysical Investigation (Magnetometer Survey)
* Soil Borings
* Soil Sampling
• Surface Water/Sediment sampling
* Drum, Tank, and Buildings Sampling
• Monitor Well Installation
• Ground Water Sampling
• Aquifer Tests
5-13
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5.2.3.1 Mobilization/Demobilization
Mobilization for the field work consists of those elements necessary to
support the field investigation team. This subtask involves orientation of
field personnel, inspection of equipment, and health and safety requirements
prior to field activity. The following activities are involved with this
subtask:
* Mobilize Field Equipment
*
*
This activity includes assembling the necessary equipment for sampling,
testing, health and safety, and decontamination. A field office trailer
may be set up which will include utility hook-ups. This subtask
includes the procurement and testing of all equipment prior to entering
the site.
Train Field Personnel
This activity includes the orientation of field personnel to the proper
sampling, health and safety, and decontamination protocols for the
Carolina Transformer site. The onsite coordinator and site health and
safety coordinator supervise this activity.
Identify Permits, Rights of Entry, and Authorization Requirements
This task consists of identifying and the necessary documents for access
to the site and private property. The SPM, with the support of Office
of Regional Counsel (ORC), will be responsible for obtaining all
documents, permits and authorizations.
5.2.3.2 Interaqency Agreement/Subcontractor Procurement
An Interagency Agreement (IGA) may be established with the Bureau of
Reclamation to conduct the RI field work. The IGA will specify the
activities the Bureau is responsible for completing. Thie will include
probably all field work and procuring and overseeing subcontracts, if they
a.,::e deemed necessary to complete the RI field work. The Bureau, or possibly
the Environmental Support Division, will perform the borings and monitor well
construction, and conduct related activities. It is anticipated that mud
rotary methods will be necessary. The monitor wells will be constructed
utilizing stainless steel screens and casing. Split-spoon soil samples will
also be collected during the installation of the monitor wells. A maximum of
twenty one monitoring wells will be constructed in clusters of three wells
per location.
Environmental Photographic Interpretation Center (EPIC) has been tasked to
develop the are aerial photographs and topographic maps of the site. EPIC
will also verify the topography of the maps. The topographic maps will
include photographic and property boundary surveys.
5-14
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Two baselines will be established on the site. One will run in an
approximately, northwest-southeast direction, the other northeast,
southwest. The baselines will cross near the approximate center of the
site.
A one inch equals 50 feet topographic map with five-foot contour intervals
will be produced. This map will include all features within an approximate
600-foot·radius of the center of the site.
5.2.3.3 Site Survey
This activity will consist of surveying the monitor wells, soil borings and
other.pertinent features identified during the RI. Each item surveyed will
be located both vertically and horizontally and referenced to mean sea level
and the state planar coordinates.
The Bureau or ESD will be responsible for surveying. They will provide
permanent field control points, baselines, and grid nodes. The baselines
will be used to establish grid points for sampling. Additionally, the
surveyor will provide horizontal points and elevations for the new wells and
prepare a topographic map of the site and immediate area.
The benchmarks and baselines will be used to establish a sampling grid over
the site. The grid will be used to establish the locations of screening
and CLP samples.
All monitor wells, sampling points and other items of interest will be
shown on the the appropriate maps.
5.2.3.4 Geophysical Investigation
A magnetometer survey will be conducted to determine if drums or tanks are
buried at or near the site. The survey will also be used to insure that no
buried drums or tanks are present at drilling locations.
5.2.3.5 Soil Sampling
The objective of the soil sampling effort is to provide sufficient data to
identify the chemical quality of local background samples, determine the
horizontal and vertical extent and nature of contaminated soil, and determine
the potential for contaminated surface soil to be entrained and transported
by the air pathway. Data will also be collected to formulate transport and
fate modeling based on the soil's partitioning capabilities. Samples will be
screened for total volatile organics. Chlorobenzene standards will be used
to calibrate the GC so that the presence of these compounds can be positively
identified. This effort will provide Level II data to be used to help make
daily decisions on-site as well as be part of the health and safety
monitoring program.
5-15
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To provide data concerning the local chemical quality of soil, a background
sample will be collected from one location (Figure 5-1). Samples collected
from soil boring CTCSB-001 will be used to represent the typical background
chemical quality of both surface and subsurface soil in the project area.
One surface soil sample will be collected. Subsurface samples will generally
be collected at five-foot intervals to a depth of approximately 100 feet.
All background samples will be submitted to the CLP for routine analytical
services (RAS).
Surface Soils
To facilitate the determination of the horizontal extent of contaminated
soil, the existing data base will be used to define a logical horizontal
extent of contamination. Prior to sample collection, this area will be
surveyed and a statistically based grid will be established on SO-foot
centers (Figure 5-2). Seventy-six (76) nodes will be established by the
grid. The grid will extend over the process area and adjacent overland
drainage paths, especially over the marsh areas northwest and southwest of
the site. Should individual grid nodes be located at misrepresentative soil
sample locations, i.e. stream beads, structures, 'ponds, etc., an alternate
location will be chosen to represent the chemical quality of the soils.
Because the north quadrant of the site was back filled as part of a previous
emergency response action, samples in this area will be collected from a
depth below the level of apparent "clean fill" and above the groundwater
table. If "clean fill" is not encountered, samples will be collected at the
land surface. If the groundwater is encountered in the "clean fill", then
the sample will be collected just above the water table. This will provide
information to determine if the groundwater was contaminated the fill. In
the area of the concrete pad, only surface samples will be collected, if
possible.
All samples collected from the grid locations will be analyzed by[[[[[[ an
onsite laboratory or local laboratory 11111 for analyses as described in
section 5.2.3.12. Approximately 25 percent of these samples will be split /
and submitted to the CLP laboratory for RAS and special analytical services q SO
(SAS). These special services could include a special oil cleanup procedure f-q /~e..
for samples obviously contaminated with oil. Oil may be present since it is l<fR"'l,u
commonly used as a carrier in wood treating processes('l:,:f not removed, this to(/
oil will interfere with laboratory analyses and result~ elevated limits of f ( /J 5
detection. 1.,v u O J I,,,./, '> ~ '"5 r
The samples sent to the CLP laboratory will be selected to include low,
medium, and high levels of contamination and thereby enable quality assurance
checks of the onsite lab analytical procedures for all levels of
contamination. The percentage of samples being sent for CLP analysis is
relatively high (approximately 25 percent) in order to verify extent of
contamination and to provide sufficient validated data for the Record of
Decision. The exact percentage and which samples will be split and sent to
the CLP will be determined out in the field.
5-16
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CTCSB-003
c:::J {!,
e CTCSB-004
Q
CTCSB-001
x-
""·· =-:=.., . SOIL BORING ER SITE
SCALE TRANSFORM CAROLINA CAROLINA NORTH NONE FAYETT.EVILLE' DATE
JANUARY 1989
5-17
FIGURE
5-1
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SC
NONE
JANUARY 1989
-
GRID/SOIL SAMPLING
C.lROLINA TRANSFORMER SiTE
FAYETTEVILLE I NORTH CAROLINA
5-18
$J
I '
1 -'j.
2
3 )(
I
4 1
F!GUF.=.
5-2
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Based on analytical results obtained from([[([( the onsite laboratory or
local laboratory]]]]]]], the horizontal extent of surface contamination will
be established. Should the actual extent not be within the established grid,
the grid will be extended and samples collected for analyses until the extent
is established. Background contaminant levels will be used as the criteria
for establishing the extent of contamination. Once a given sample is
determined to be "clean," an additional sample farther out will be taken to
verify the extent of contamination. As indicated in Table 5-2, a total of 50
extent of contamination samples are proposed, but the exact number will be
determined in the field.
Once the horizontal extent has been established, soil samples will be
collected at a node of the grid, one node in from the established perimeter
of contamination at a depth of three feet below the previously collected
sample to test the depth of horizontal contamination. The purpose behind
this sampling is to maintain that the actual lateral extent of contamination
has not been misinterpreted because of a sloping contaminated soil
interface. Results from this sampling will also provide an indication of the
shape of contaminant extent, i.e. an upright or inverted bowl. Full
analytical scans will be ran on these samples by the([[[[[ onsite laboratory
or local laboratory JJJJJ. Twenty-five percent of the samples will be
analyzed by the CLP for RAS and SAS. Approximately 30 samples will be
collected.
Subsurface Soils
To determine the vertical extent of contamination, split spoon samples will
be collected from six (6) boreholes (Figure 5-l). The boring will be done
using mud rotary drilling. A representative sample of the drilling mud will
be analyzed by the([[[[[ onsite laboratory or local laboratory]]]]] and the
CLP laboratory. Mud rotary drilling is the preferred method for the
following reasons:
o The method is effective on lithologies ranging from flowing sands to
cohesive clays. The need for identifying alternate methods and planning
contingencies for alternate methods in the field are reduced.
o The mud cake which will form on the borehole walls will prevent
potentially contaminated ground water from mixing between aquifers and
biasing results.
o Borehole abandonment may be performed with the highest level of
confidence because cave-in is prevented by the column of drilling mud.
Figure 5-1, shows locations of the six ,(6) deep boreings with one boring,
CTCSB-001, to be identified as the background boring. Split spoon samples
will be taken continuously starting at a depth of five feet until the
confining unit of the upper aquifer is reached. A sample will be taken here
to determine if contaminants are collecting on the surface of this confining
unit. If a confining unit between the upper and middle aquifer is not
encountered, continuous sampling will occur until the confining unit between
5-19
- -- --- --
TYPE
SAMPLE
Grid Samples
'-" At Surface 76 76 9
' '.' Grid Samples ,=, At Depth 40 40 5
fi~ckground
At Surface/Depth 15 15 2
Greb Sam12lee 20 20 3
.Confirming Extent
of Contamination 60 60 8
Vertical Extent 70 70 9
SUBTOTALS 281 281 36
Duplicates 28 28 4
Blanke 4 4 1
Spikes 4 4 I
11 11
TOTALS I I 31 7 11 JI 7 42
CLP-Contract Lob Program PCBa-Polychlorinated
--·---TABLE 5-2
SOIL SAMPLING ANALYTICAL PARAMETERS
CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
-
ANALYTICAL PARAMETERS
Local Lab
25
13
15
7
20
28
108
11
4
4
11
I I I 2 7
Biphenyle
15
7
3
3
12
15
55
5
4
4
68
CLP
11
11
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RAS-Routine Analytical
FIELD
20
20
11
11 20
Services
-- - - -
OTHER
NOTES1
2 Horizon Lal Extent
Vertical Extent
At Surface
Partitioning
2
AEproxifflatel:l£ IOI
One {!:er week
One [!er week
11
2 11
TOC-Total Organic Carbon
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the middle and lower aquifer is reached. Assuming a confining unit is
encountered, sampling will continue at approximately five-foot intervals
until the bottom confining unit of the lower aquifer is reached. The final
borehole sample will be taken here to determine if contaminants are
collecting on the surface of this confining unit. The total depth of each
borehole will vary depending on geologic characteristics at the selected
point but should not exceed 100 feet. Approximately 84 samples will be
collected. Each sample will be analyzed according to the previously
mentioned schedule. In addition, several of these samples will be analyzed
for total organic carbon (TOC) to provide data necessary to calculate and
determine partitioning coefficients. Boreholes will be abandoned by tremming
a cement/bentonite grout to the surface.
Additional Soil Sampling
Two surface soil samples will be collected from the site and analyzed for
grain size distribution (sieve and hydrometer analyses) to determine the
potential risks associated with airborne particulates. These samples will be
· collected from onsite in areas not covered with fill material.
Other soil samples not within the grid may be located based on visual or
historical evidence of contamination. A maximum of fifteen (15) such grab
samples are predicted. A location already known to require grab sampling
include the wooded area north and west of the site. Approximate sampling
points are shown in Figure 5-3.
Decontamination
Decontamination procedures for equipment used during the soil sampling
subtask are.detailed in the Carolina Transformer Site Project Operations
Plan. All decontamination solutions, milli-Q water, soil, mud, etc., removed
with the high pressure washer will be disposed of oneite. The
pesticide-grade isopropanol will be collected and allowed to evaporate. Any
residual isopropanol that remains unevaporated will be properly packaged and
disposed of in accordance with applicable regulations. spent decontamination
solutions will not be allowed to flow offsite. A work assignment amendment
will be required if additional decontamination solution collection and
disposal procedures are required based on site conditions and/or new EPA
directives.
5.2.3.6 Surface Water/Sediment Sampling
Surface water/sediment sampling will be conducted to determine the extent and
magnitude of surface water contamination. Surface water/sediment samples
will be collected from ten (lO) locations in the immediate vicinity of the
site to characterize the marsh areas northeast and southwest of the site, any
standing pools of water in the wooded area north of the site and the drainage
ditch/unnamed stream (several locations) leading to Cape Fear River. Surface
water/sediment sampling points are shown in Figure 5-4. Analytical
parameters to be tested for each sample are shown in Table 5-3.
5-21
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All surface water and sediment eamplee, approximately 20, will be eent to the
CLP laboratory for the RAS and SAS, if needed. In addition to collecting the
eamplee, field meaeuremente will be taken for pH, temperature and
conductivity.
5.2.3.7 Drum, Tank, and Building Sampling
Numerous, rusted drums, three partially buried fuel storage tanks, and six
transformers are located onsite. Approximately 20 of the drums may contain
waste fluid and several are bulging.
These drums are located at several places onsite. In addition numerous
empty, rusted drums are located on the site. Samples (Figure 5-5) will be
collected from the drums, fuel storage tanks, and transformers containing
liquids, following protocols given in the POP. All eamplee will be eent to
CLP laboratories for RAS.
Three onsite buildings will be sampled by collecting soil from the floors and
taking wipe samples from walls and counter tops. The buildings include a
main office and loading dock, a four bay garage and a small brick shed
containing empty drums and paint cans. Fifteen soil and five wipe samples
will be collected in the buildings and eent to CLP laboratories for RAS.
5.2.3.8 Monitor Well Installation
This task consists of drilling, installing, and developing permanent monitor
wells. Six clusters (maximum of three wells each) will be installed in the
approximate locations shown in Figure 5-6. A seventh monitor well cluster
may be installed, based on GC screening results of split spoon samples taken
during the installation of the other eix monitor wells. One cluster (MW-ls,
M, and D) will be located oneite, south of the concrete pad eo that the
vertical extent of contamination can be determined. The remaining clusters,
MW-2 through MW-6, will be located around the periphery of the site to aesese
the degree of offsite contaminant migration. At least one of these wells
will be upgradient of the eite to provide background groundwater quality.
The actual number of monitor wells in a cluster, the location of the clusters
and depth of the monitor wells will be determined by evaluating the data
provide by Section 5.2.3.5, the six (6) deep soil borings. Site conditions,
such as accessability, will also be considered. This information will allow
the on-site geologist to determine the number of aquifers at the site and
therefore, the number of wells necessary in each cluster.
Figure 5-7 shows cluster well construction. Monitor wells will be
constructed of two-inch inner diameter, 316 stainless steel casing and
screen. Screens will be at least ten feet long; slot size will depend on
results of grain size analyses conducted on selected samples collected during
initial soil borings; however, it is anticipated that 0.01 inch slots will be
5-22
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,: 0:
0 ::J ... (.') .., ., -0 u. f;l 0 ,-l
r,Q
" "' ~ ,: ... .... "'
r X
~ "'
• "' z 0
H !-< ~
" z
H
,-l ~ "'
,-l
H 0 "'
:;J z 0 H
!-< H
0 ~
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w ~--(/)
er w
2 er
0 u.
(/)
z
<( er I-
<(
7.
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0 n::
<(
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<( z
_J
0 er
<I
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UJ
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<(
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"' 0)
"' .-,
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U')
-------------------
--
SCALE
NO SCALE
-
0 ATE
,lMUARY 1989
--- - - - - - ---
PROPOSED SURFACE WATER/SEDIMENT SCREENING LOCATIONS
CAROLINA TRANSFORMER SITE
FAYETTEVILLE I NORTH CAROLINA
- - - - -
,?,'
.---------------SW-09
(approx. 800 ft.
on Locks Creek)
._________
SW-10 ·•
(approx.
on Locks
BOO ft.
Creek)
F iGURE
5-4
-------------------
SAHPLE
SW-01 thru SW-10
"' ' ,,,
"'
SUBTOTALS
nunlicates
Blanks
seikes
TOTALS
CLP-Contract Lab
f-< j
H fJ ~ ::f
0 .,
II 11
11 10 10 11
11 11
11 11
11 11
11 I 11
11 10 10 I 11
11 I 11
11 2 I 2 I 11
11 I I 11
11 1 I 1 I 11
11 I I 11
11 1 I 1 I 11
11 11
11 14 14 11
TABLE 5-3
SURFACE WATER/SEDIMENT SAMPLING ANALYTICAL PARAMETERS
CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
ANALYTICAL PARAMETERS
Local Leib CLP FIELD
11 11 11
11 10 10 11 10 10 10 11
11 11 11
11 11 11
11 11 11
11 I I 11 I 11
11 10 I 10 I 11 10 10 I 10 11
11 I I 11 I 11
11 2 I 2 I 11 2 I 2 I 2 11
11 I I 11 I I 11
11 1 I 1 I 11 I I 11
11 I I 11 I I 11
11 1 I 1 I 11 I 11
11 11 11
11 14 14 11 12 12 12 11
Program PCBs-Polychlorinated Biphenyle RAS-Routine Analytical Services
OTHER
HOTES1
11
11
11
11
11
11
11
11
11 Aeeroximateli 201
11
11 One eer week
11
11 One Eer week
11
11 TOTALS
TDC-Total Organic Carbon
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EDGE
PROPERTY
c::J t1
SCALE
NO sc:.t.:.E
DA TE
JANUARY 1989
Oo
□
LARRY'S
MAIN OFFICE
BUILDING
0 SAUSAGE CO.
OTHER AREAS REQUIRING SAMPLING
CAROLINA TRANSFORMER SITE
FAYE:TTEVILLE ,NCRT:-1 C.lRCLlN.l.
5-26
MIDDLE
ROAD
LEGEND
•ABANDONEO
TRANSFORMER
o DRUMS
e FUEL STORAGE
TANKS
FIGURE
5-5
-- -
SC ALE
- - -
·-4;:~
MWS-13 ·•
MWD-14 •
(if needed
-- - - - - -
• MWS-07
MWD-08
NO SCALE PROPOSED MONITOR WELL CLUSTER LOCATIONS
DATE . CAROLINA TRANSFORMER SITE
- - - - - -
LEGEND
• Sample Location
FIGURE
5-6
JANUl\RJ 19AQ FAYETTEVILLE, NORTH CAROLINA ..L._ __________ ~ ___ _:..::.::.:..:__:_:_:_=:..'....:.::~:....:.:.::.:..:..:.::.:.:.:.._ _____________ ........1... __ ~
I CAP. WITH
I LOCK
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I BENTONITE/
CEMENT
I GROUT~
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1·
•
,----.4• DIA. STEEL
CASING
2· STAINLESS.
STEEL CASING CONCRETE
PAO-~
-r--:::---r
10
(II
8' BOREHOLE
·o ....
BENTONITE/
CEMENT GROUT
s· BOREHOLE
.-"-HEN TONI TE
PELLET SEAL
2· DIA.
STAINLESS
STEEL SCREEN
..__ SANO PACK
WATER TABLE ZONE
UPPER CONFINING UNIT
.--2· STAINLESS STEEL
CASING
, BENTONITE
PELLET SEAL
6'BOREHOLE
,,--2· DIA. STAINLESS
STEEL SCREEN
LOWER CONFINING UNIT
FIGURE NO.
CLUSTER WELL CONSTRUCTION
CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
5-28
5-7
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used. A sand pack will be installed from the bottom of the borehole to two
feet above the top of the screen. Above the sand pack the annulus is sealed
with two feet of bentonite pellets which will be allowed to hydrate for a
minimum of eight (8) hours. The remaining annular space will be filled with
cement/bentonite grout. All wells will be drilled according to Region IV SOP
and in accordance with Title 15 North Carolina Administrative Code Subchapter
2C (Well Construction Standards, Criteria and Standards Applicable to Water
Supply and Certain other Type Wells).
As identified is Section 3.1.1.1, there is no site specific hydrogeological
data available. It is anticipated that two (2) and possibly three (3)
aquifers exist beneath the site. The information obtained from the soil
borings (Section 5.2.3.5) will answer this question. For purposes of
preparing this work plan, the installation of two monitor wells, one in the
upper most aquifer (the shallow aquifer) and one in the aquifer below the
shallow aquifer is described. If three (3) separate aquifers are determined
to exist, the deepest aquifer will only be monitored if contamination is
found on the middle aquifer. The installation of a monitor well into this
deep aquifer would require installing two (2) protective casings, each
protective casing anchored into the aquitard encountered while drilling down
to the deep aquifer.
All monitor wells will be developed by air surging or pumping until the
discharge water is free of visible sediment and drilling fluids.
Temperature, pH, and conductivity readings will be taken during development.
Development will continue until these readings stabilize. Water generated
due to well development will be collected and discharged to a shallow trench
dug nearby and allowed to percolate into the ground.
At each cluster location, the deeper well be installed first. This will
provide additional information to help determine the optimal depth for the
shallow monitor well screen.
A mud rotary method, using a bentonite drilling fluid to maintain hole
stability, will be used to install all monitor wells.
Middle and Deep Well {if needed) Installation
At each well cluster location, split spoon samples will be collected
continuously until the lower confining unit of the upper aquifer is
encountered. A six (6) inch diameter steel casing will be installed from the
ground surface to this confining unit. The casing will then be pushed one
foot into the clay or until the unit resists penetration. The casing will
then be grouted in place using a tremie pipe. The grout will be allowed to
set for 48 hours before further work is performed on the well. An eight (8)
inch steel casing will be used if three (3) aquifers were determined to exist
during the deep boring task.
If another confining unit is determined to be present (i.e., a three aquifer
system), the above procedure will be followed using an eight-inch steel
casing first, succeeded by the six-inch steel casing. In this case, the 6
inch steel casing will be anchored into the second aquitard.
5-29
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The remainder of the borehole will then be drilled, and split spoon samples
collected at five-foot intervals to a depth corresponding with the bottom
confining unit of the lower aquifer. The well will be completed with ten
feet of two-inch diameter stainless steel screen with the screen bottom.
located at the bottom confining unit of the lower aquifer. The remainder of
the well will be constructed with stainless steel riser pipe, sand pack,
bentonite pellets and grout.
Shallow Well Installation
Prior to the installation of shallow wells in or near the process area
(MWS-01 or MWD-02), a well point will be installed in a hand-augured hole and
screened such·that the water table surface is intercepted. The annulus will
be backfilled with sand and pumped until free of sediment. After 24 hours,
an unmixed column of water will be collected and inspected for the presence
of "oil" floating on the water. If "oil" is observed, the top of the screen
will be located below this level. It is critical, however, that the screen
bottom rest on top of the clay layer between the upper and middle/lower
aquifers. If observed, the "oil" will be sampled for analyses.
Shallow wells will be installed so that the screened interval intercepts the
water table. The screen length will be sufficient to extend above and below
the water table to allow for seasonal water fluctuations.
All monitor wells will be developed by over pumping, and surging if
necessary, until the water is free of visible sand and drill fluids.
Developed water will be monitored for conductivity stabilization. Protective
casings will be installed over all new monitoring wells to prevent
unauthorized tampering with the wells.
Shelby Tubes
To assess the potential for contaminant transport between the aquifers, three
(3) Shelby Tubes will be collected from each clay layer between the aquifers
during installation of the deep monitor wells. Because continuous split
spoon sampling will be done during well installation, the confining layer
between the aquifers can be identified and sampled. The possibility exists
that the clay layer may be drilled through without collecting a Shelby Tube
if the clay layer is encountered sooner than expected and is thought to be a
clay lens rather than the confining layer. If this occurs, the Shelby Tube
will be collected when drilling the companion well in the well cluster. The
shallow well will be drilled to the clay layer identified during deep well
installation, the Shelby Tube collected, and the shallow well backfilled with
bentonite up to the desired screen depth. Locations for Shelby Tube
collection will be selected based on geographic·distribution determined by.
the data gathered through the deep borehole task. If the confining layer is
absent at one or more of these locations, new location(s) will be chosen in
the field. Laboratory permeability tests will be conducted on Shelby
samples.
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5.2.3.9 Groundwater Sampling
Groundwater samples will be collected from the monitor wells (maximum of 21)
and possibly 10 domestic wells (Figures 3.3 and 5.4) to determine the extent
and magnitude of ground water contamination. All wells installed during this
investigation will be purged and sampled according to the procedures outlined
in Region IV, ESD SOPe. The water level in each well will be measured and
the total volume of the water column calculated. A minimum of three well
volumes of water will be purged from the well. Conductivity, pH, and
temperature will be measured and recorded during purging. When these
parameters stabilize and after a minimum of three well volumes have been
removed, purging will cease. Samples will be collected using a closed top
stainless steel or teflon bailer. Samples will be sent to a CLP laboratory
for RAS analysis.
If domestic wells are sampled, the sample will be collected as close to the
well head as possible. Depending where the sample can be obtained from the
pluming system will determine the length of time necessary to purge the
system. These samples will be sent to a CLP laboratory for RAS analysis.
The necessity of sampling domestic wells will be determined out in the field.
Groundwater·eampling points are shown in Figure 5-8. Analyses for these
samples are shown in Table 5-4.
5.2.3.10 Aquifer Testing
After the completion of monitor well sampling, in situ hydraulic conductivity
tests of saturated materials will be performed on all the medium and deep
monitor wells (a maximum of 14 wells in seven clusters). These teats are
commonly referred to as slug tests. These tests involve instantaneously
displacing a known volume of water in the well and measuring the recovery
rate with pressure sensitive water level transducers. The data generated
from these tests will be used to define the water-yielding characteristics of
the formation near the well, estimate groundwater velocity values, and
estimate the rate of groundwater movement in the vicinity of the site. Since
these tests will be performed in each well of a cluster, the degree of
vertical heterogeneity within the aquifer can also be determined. A maximum
of 14 slug tests will be performed.
5.2.3.11 Water Level Measurement
Water level measurements will be taken at least two times during the RI at
all the monitor wells (Figure 5-4). All water level measuring activities
will be performed within one day so that levels will be comparable. Each
measurement will be made from a known point of elevation marked on the well
casing, as surveyed by a licensed surveyor. These levels will allow flow
directions in the upper and lower aquifers to be established.
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DW-05 e
-= A ST:=ol\1 _,
1-{J,.j';' 3 0 f >
FIGURE 5-B
MWS-09
MWD-10 •
DW-04•
MWS-11
MWD-12•
• MWS-13
MWD-14 •
.BLVD oz 9.::
DW-01 •
MWS-07
MWD-08 •
MWS-01 MWD-02 • MWS-05 .MWD-06•
7 ng Locations Groundwater Sampl.
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~
h'OL I,..., -I ;,,./CO/)
8.!..YL>
-------------------
SAMPLE
11
Monitor Welle 11 ,n
' 11 '.' {,_) Domestic Welle 11
11
11
11
SUBTOTALS 11
11
nuelicates 11
11
Blanke 11
11
~Qikee 11
11
TOTALS 11
CLP-Contract Lab Program
11
14 11
11
10 11
11
11
I 11
24 I 11
I 11
3 I 11
I 11
1 I 11
I 11
1 I 11
11
29 11
TABLE 5-4
GROUNDWATER SAMPLING ANALYTICAL PARAMETERS
CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
ANALYTICAL
Local Lab CLP
11 11
11 14 14 11 14 14 14
11 11
11 10 10 11 10 10 10
11 11
11 11
11 I 11 I I
11 24 24 I 11 24 I 24 I 24
11 I 11 I I
11 3 I 3 I 11 3 I 3 I 3
11 I I 11 I I
11 1 I 1 I 11 I I
11 I I 11 I I
11 1 I 1 I 11 I I
11 11
11 29 29 11 24 24 24
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
PCBe-Polychlorinated Biphenyls RAS-Routine Analytical Services
OTHER
NOTES,
11
11
11
11
11
11
11
11
11
11 AeEroximatell:'. 1 0%
11
11 One eer week
11
11 One Eer week
11
11 TOTALS
TOC-Total Organic Carbon
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5.2.3.12 Analytical Procedures
Analytical services provided by subcoOtracted laboratories will include grain
size analyses (sieve and hydrometer analyses) as described in Section
5.2.3.5.
An onsite or local laboratory is required to provide quick turnaround of
analytical results that are necessary to verify the exte~t of contamination
of soil and ground water. The laboratory will be provided through
subcontracting agreements established on the basis of technical capability
and cost competitiveness.
The laboratory will be equipped to perform analyses for the following
parameter types:
Type 1 -???????????????????????????????????????????????????????????????
Type 2 -Benzene, toluene, and total xylenes in water and soil/sediment
samples according to EPA Method 602.
Type 3 -PCBs in water and soil/sediment samples according to EPA Method 610.
Samples analyzed by the CLP laboratory include approximately 25 percent of
all soil samples, all surface water/sediment samples, and all ground water
samples. Samples submitted to the CLP will be subjected to the Routine
Analytical Services (RAS) for the Hazardous Substance List (HSL).
Approximately 15 percent of the samples will require Special Analytical
Services (SAS) to analyse for dioxins. In addition, samples that apparently
contain high concentrations of oil will require additional sample preparation
procedures to maintain detection limits within the data quality objectives.
5.2.3.13 Technical/Financial Management
Refer to Section 5.2.1.10.
5.2.3.14 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.4 SAMPLE ANALYSIS/VALIDATION
The sample analysi_s/validation task includes all work efforts related to
monitoring the analysis of the samples after they leave the field.
5.2.4.1 Sample Management
All sample management procedures used during this investigation will be in
accordance with appropriate EPA Region IV standards as described in the POP.
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5,2,4.2 Analytical Laboratory Procedures
All analytical laboratory analyses and laboratory quality assurance
procedures will be in accordance with applicable EPA methodologies for sample
storage, preparation, analyses, and data interpretation. These methodologies
include those referenced in 40 CFR, Subchapter D, Part 136 -Guidelines
Establishing Test Procedures for the Analysis of Pollutants.
5.2.4.3 Contract Laboratory Data Validation
Validation of the analytical laboratory data received from the contract
laboratories will be done by EPA Region IV or their contract employees,
depending on availability of EPA personnel.
5.2.4.4 Technical/Financial Management
Refer to Section 5.2,1,10.
5.2.4.5 Quality Assurance/Quality Control
Refer to Section 5.2.1,11.
5,2,5 DATA EVALUATION
The data evaluation task includes work efforts related to the analysis of the
data once they have been verified for acceptable accuracy and precision.
5,2,5,l Data Analysis
All data resulting from field investigations will be reviewed as part of this
subtask, These data include well construction details, water level
measurements, water quality measurements, and soil/sediment contamination
measurements.
5.2.5.2 Data Reduction and Tabulation
All data collected in the field and measured in the laboratory will be reduced
and tabulated in a systematic manner to facilitate data review and analysis.
These data includes well construction details, water level measurements and
environmental quality measurements, etc. The data reduction process_may
include computer analysis, graphic representation or other methods that aid in
the analysis of the data and conceptualization of the results. All raw data
will be appendiced in the RI Report.
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5.2.5.3 Environmental Fate and Transport
The remedial alternative eventually selected by EPA for this site will depend
on the source, level, and extent of contamination resulting from activities on
the site. contaminant transport modeling of the site will utilize existing
data to develop a concept of contaminant migration via both surface and ground
water. This system conceptualization is based on the geology, hydrology,
source, and contaminant data obtained on the aquifer system and local surface
water drainage. The system conceptualization qualitatively describes aspects
of the hydrogeologic system such as boundary conditions and recharge,
directions of flow, surface features, relative values of hydraulic properties,
and geologic layering. This subtask does not include computer simulation.
Contaminant transport modeling using computer simulation may occur as part of
Task 14 (Miscellaneous Support).
5.2.5.4 Technical/Financial Manageffient
Refer t'o Section 5. 2. 1. 10.
5.2.5.5 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.6 RISK ASSESSMENT
The risk assessment task includes all work efforts associated with assessing
the potential impacts on public health, welfare, and the environment from
actual or potential releases resulting from past activities at the site.
5.2.6.1 Public Health Evaluation
The public health evaluation, described in detail below, addresses the
potential human health and environmental effects associated with the Carolina
Transformer Site under the no action alternative. The no action alternative
assumes that no remedial (corrective) actions take place at the site and that
no restrict.ions are placed on the future use of the site. Evaluation of the
no action alternative is required under section 300.68 (f)(v) of the National
Contingency Plan (NCP). By conducting such an assessment, EPA will be able
to determine if remedial actions are indicated for any area of the site. In
addition, the baseline assessment will provide a basis for determining the
reduction in risk resulting from remediation.
The baseline public health evaluation.will be based on the remedial
investigation environmental monitoring, biological sampling data, and other
information (e.g. hydrogeological characteristics of the site) collected
during the remedial investigation, and will be coordinated with any
biological study conducted by the U.S. Fish and Wildlife Service and the EPA
Environmental Services Division. The main steps in the assessment, which
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will be performed in accordance with the latest EPA guidance on risk
assessment in general, and for Superfund sites in particular, are outlined
below.
Select Compounds for Hazardous Assessment
The first step in the public health evaluation will be to review the results
of the environmental sampling and other information developed during the RI
to identify chemicals of potential concern for detailed study. Key elements
in this screening process are a comparison of site concentrations to
background levels of chemicals in appropriate media. Naturally occurring
chemicals present at background concentrations will not be considered to be
site-related and will not be evaluated in the assessment. In addition,
chemicals present in blanks at similar concentrations (i.e., laboratory and
contaminants) will not be selected for the detailed analysis. Since a
relatively small number of chemicals have been detected in preliminary ground
water samples at the Carolina Transformer Site, it is anticipated that this
is the only screening that will be necessary. If further selection is
needed, relative concentration, mobility, persistence, and toxicity of the
contaminants in the environmental samples (air, water, sediment and soil)
taken at the site will be considered to complete the identification of
chemicals of concern. Preliminary information indicates that PCBe, at a
minimum is likely to be selected as a chemical of concern at the site.
Assess Exposure to Human and Environmental Receptors
The objective of an exposure assessment is to identify actual or potential
routes of exposure and characterize the likely magnitude of exposure to human
or environmental receptors. The environmental risk assessment is anticipated
to be a critical component of the endangerment assessment. The U.S.
Department of Fish and Wildlife has taken responsibility for assessing the
ecological/environmental risks associated with this site to the extent it is
deemed necessary.
Potential human exposure pathways that may be important under current or
future land use conditions include direct contact with contaminated soil,
surface water, or sediment, and use of ground water as a potable water
supply. These exposures will be characterized by constructing exposure
scenarios. Each exposure scenario will define the source of contamination,
the route of transport, possible receptors, and the likely routes of exposure
(ingestion, inhalation, or direct contact). For each exposure scenario,
concentrations in relevant environmental media (air, surface water, sediment,
ground water, soil) at the potential receptors' locations will be
identified. Where concentrations have not been measured at the exposure
point, estimates of current concentrations may, in certain instances, be made
using models. For example, air transport modeling will be necessary to
estimate the potential for inhalation exposure to airborne particulates
originating at the Carolina Transformer Site. In addition to the estimation
of concentrations for current exposures, modeling may be necessary to predict
future concentrations, particularly for leaching of wastes from the onsite
impoundments, the drainage ditches or the adjacent swamp area into the ground
water. Chemical intakes for each human exposure scenario will be estimated
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based on frequency and duration of exposure and rate of media intake (e.g.,
amount of air breathed each day). The assumptions used in these estimates
(e.g., activity patterns, consumption of ground water, inhalation rates,
absorption factors) will be stated clearly and documented to the extent
possible. The assumptions will be selected to represent an "average exposure
case" and a "plausible maximum case".
The exposure of non-human receptors will be treated qualitatively, if
necessary, based on ambient environmental concentrations of site-related
chemicals of potential concern. However, as noted above, the U.S.
Department of Fish and Wildlife has taken primary responsibility for
assessing environmental risks posed by the site.
Assess Toxicity
In this step, critical toxicity values will be identified for each chemical
of potential concern. In the quantitative risk assessment, these toxicity
values will be combined with the intake values described above.
For humans, toxicity data will be presented in the following forms:
o For carcinogens, the carcinogenic potency factor, in the units
(mg/kg/day)-1 ;
o For non-carcinogens, the estimated risk reference dose (RfD) (formerly
called acceptable daily intake [ADI]) in the units mg/kg/day;
o For chemicals for which no critical toxicity values are available, a
semi-quantitative ch~racterization based on any pertinent information
that is available (e.g., subchronic toxicity studies or structural
analogies) will be performed, if necessary. The basis for any toxicity
values developed by EPA for this assessment will be provided.
In addition to critical toxicity values, any Applicable or Relevant and
Appropriate Requirements (ARARs) that have been established for the potential
chemicals of concern will be identified. Currently, EPA considers maximum
contaminant levels (MCLs) and maximum contaminant level goals (MCLGs)
developed under the Safe Drinking Water Act, federal ambient water quality
criteria (AWQC), national ambient air quality standards (NAAQS), and state
environmental standards to be potential ARARs for use in risk assessments at
Superfund sites.
If conducted, the results of acute and chronic aquatic toxicity testing will
be evaluated to assess the overall toxicity of site contaminants and to allow
for determining or predicting compliance with state water quality standards.
Assessment of Risks to Human Populations
According to the procedures for public health evaluations developed by EPA,
the potential adverse effects on human health should be assessed where
possible by correlating concentrations found at or near the site with ARARs
that have been developed. However, if suitable ARARs are not available for
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all of the selected indicator chemicals and for the exposure scenarios
considered, a quantitative risk assessment must also be performed for all of
the chemicals of potential concern. It is anticipated that ARARa will not be
available for all of the chemicals of concern or for all environmental media
(e.g., soil) that will be considered in this aaaeaament.
The evaluation of non-carcinogenic health risks associated with contaminants
of concern considered in this report is based primarily on a comparison of
the estimated daily intake of the indicator chemicals with appropriate
critical toxicity values for the protection of human health described above.
For potential carcinogens, the estimated cancer risks _associated with
exposure are calculated using EPA-derived cancer potency factors.
Specifically, excess lifetime cancer risks are obtained by multiplying the
cancer potency factor by the average daily intake of the contaminant under
consideration. This procedure is considered to be appropriate for low doses,
such as would potentially result from this site. In this aaaeaament, the
effects of exposure to each of the contaminants under the scenarios evaluated
will initially be considered separately. However, pollutants occur together,
· and individuals may be exposed to a mixture of the contaminants.
Consequently, it is important to recognize the potential adverse effects that
these mixtures can have in humans.
Suitable data are not available to characterize the effects of chemical
mixtures potentially present at or near the Carolina Transformer Site. As
suggested in EPA guidance for evaluating mixtures, however, it may be useful
to sum the excess cancer risks or to calculate hazard indices for chemical
mixtures.
Riek aaaeaamenta will be conducted separately for each exposure pathway and
for each source when appropriate. Results will be presented separately for
the "average exposure case" and the "plausible maximum case" exposure
assumptions. The risk aaaeaament for each exposure pathway will include a
discussion of the uncertainties in the estimates.
Assess Environmental Impacts
The extent of potential impacts on the environment, including plants,
animals, and other aesthetic resources, will be evaluated, if necessary.
Thia assessment will be based on estimates of ambient concentrations of
chemicals of concern in environmental media derived earlier. The likelihood
of significant exposure by predatory species via the food web will also be
considered. However, the U.S. Department of Fish and Wildlife has taken
primary responsibility for aaaeaaing environmental impacts, and consideration
of these issues is likely to be minimal in the public health evaluation.
5.2.6.2 Technical/Financial Management
Refer to Section 5.2.1.10.
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5.2.6.3 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.7 TREATABILITY STUDY/PILOT TESTING
This task includes any efforts related to conducting pilot, bench scale, and
treatibility studies. These activities will be performed as necessary,
depending on results of the RI and review of available remedial
technologies. Because the amount of information is already quite substantial
for those technologies most applicable to site contamination from PCBs, it is
anticipated that minimal, if any, activity will be undertaken under this
task. If pilot, bench scale, or treatibility studies are conducted, acute
and chronic toxicity studies may be performed on treated effluent.
Any activities beyond an initial response acknowledging the need for pilot,
bench scale, or treatibility studies will require additional budget
allocations.
5.2.7.1 Report Preparation
If treatability studies or pilot testing is conducted, a report documenting
all activities will be prepared. This report would include sections on test
facility and equipment procurement, vendor procurement, equipment operation
and testing, sample analysis and validation, testing results, evaluation of
process(es), and conclusions.
5.2.7.2 Technical/Financial Management
Refer to Section 5.2.1.10.
5.2.7.3 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.7.3 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.B REMEDIAL INVESTIGATION REPORT
The RI report task includes all work related to the documentation of the
results once the data have been evaluated and the risk assessment performed.
This task covers both the draft and final RI report.
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5.2.8.1 Draft Report Preparation
Following completion of the data evaluation and risk assessment tasks, a
draft RI report will be prepared for review. The report will include updated
soil data, water quality data and site specific hydrogeologic data. The
report will also contain monitor well construction details, contaminant
source and migration evaluation results, risk assessment results, possible
remedial activities, and conclusions and recommendations.
Thie subtask encompasses several activities including writing text for the RI
report; preparing graphics such as site maps, plume diagrams, hydrogeological
cross-sections, sampling locations, and organizational charts; and printing
and distributing the RI report.
The report will address the following:
'* Soil quality data
• Surface water and sediment quality data
• Ground water quality data
* Monitor well construction details
• Results of the geophysical investigation
• Updated site-specific hydrogeologic data, including all slug test
results and water level data
* Contaminant source and migration evaluation results
• Conclusions and recommendations based on data collected during the
field investigation.
5.2.8.2 Graphics Preparation
Thie subtask includes the preparation of all graphics to be included in or
with both the draft and final RI report. These graphics may include, but are
not limited to:
• •
*
* •
*
*
*
*
* • • •
*
Site maps, including topographic contour maps
Water level maps
Plume diagrams
Well construction diagrams
Hydrogeological cross-sections
Well location maps
Sampling location maps
Organizational charts
Water level contour maps from each well depth
Water level tables of each screen elevation
Contaminant-specific plume diagrams of each screen elevation
Contour map of depth to bedrock surface
Borehole logs
Surface geophysical survey results
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5.2.8.3 Technical Review
A Technical Review Committee (TRC) meeting may be held as part of quality
control to discuss and evaluate the results, conclusions, and recommendations
stated in the draft RI report. After completion of the meeting, minutes may
be prepared and distributed to all TRC participants. In addition, a
follow-up memorandum outlining the actions or report modifications occurring
as a result of the TRC meeting may be distributed to all TRC members as is
appropriate.
5.2.8.4 Draft Report Printing/Distribution
This subtask includes all work associated with reproducing and distributing
the draft RI report to the appropriate review parties. Fifteen copies are
anticipated for distribution.
5.2.8.5 Review Meeting
A review meeting may be held with representatives from all the appropriate
review agencies and parties to discuss the results, conclusions, and
recommendations in the draft RI report. After completion of the meeting,
minutes may be prepared and distributed to all review meeting participants.
In addition, a follow-up memorandum addressing all comments submitted in
writing by the review meeting participants may be prepared and submitted to
EPA.
5.2.8.6 Final Report Preparation
After EPA and other agency review of the draft RI report, a final RI report
will be prepared for submission to EPA. All appropriate comments generated
by the review participants will be incorporated in the final report.
5.2.8.7 Final Report Printing/Distribution
This subtask includes all work associated with reproducing and distributing
the final RI report to the appropriate parties, as directed by EPA. This
subtask will also be performed as part of the draft FS report task.
Approximately 15 copies are anticipated to be needed.
5.2.8.8 Technical/Financial Management
Refer to section s.2.1.10.
5.2.8.9 Quality Assurance/Quality control
Refer to Section 5.2.1.11.
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5.2.9 REMEDIAL TECHNOLOGIES SCREENING
5.2.9.1 List All Potential Technologies
During this subtask, which is the first subtask of the feasibility study, the
most appropriat8 remedial technologies will be identified based on available
data. The potential component technologies identified in Section 4.1 will be
considered for the feasibility study. Additional technologies may be
developed depending on results of the remedial investigation.
5.2.9.2 Technical Feasibility Screening
The remedial technologies listed through efforts described in Section 5.2.9.1
will be screened for technical feasibility and ranked relative to their
potential for implementation at the Carolina Transformer Site. Technical
feasibility is primarily focused on issues related to implementability,
performance, and reliability of the proposed remedial technologies.
Implementability relates to whether the system can be built on the intended
site, performance relates to whether the technology will be effective over
its useful life, and reliability is concerned with previous favorable
experience with the system under comparable operating situations and whether
there will be excessive or frequent down time.
5.2.9.3 Environmental and Public Health Screening
Potential remedial technologies will also be screened for environmental and
public health impacts. Environmental and public health screening relates to
several factors. Specific areas of interest include existing conditions and
their impacts (baseline assessment), environmental and public health impacts
during implementation and operation of the remedial technology, and impacts
during decommissioning of remedial systems.
5.2.9.4 Cost Evaluation
cost of each remedial alternative will be examined to identify any gross
variations in anticipated capital, annual operating or net present value
costs. This preliminary screening is employed to identify any cost
consideration that would compromise the viability of one technology relative
to others.
5.2.9.5 Technical/Financial Management
Refer to Section 5.2.1.10.
5.2.9.6 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
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5.2.10 REMEDIAL ALTERNATIVES EVALUATION
The objective of the remedial alternatives evaluation is to complete a
detailed evaluation of those remedial actiqns that have passed the initial
screening. Detailed evaluation of each remedial alternative will include
consideration of the following:
o Technical feasibility
o Public health impacts
o Environmental effects
o Institutional requirements
o Cost factors
s.2.10.1 Technical Feasibility
Technical feasibility includes consideration of the implementability,
reliability, and performance of the remedial alternatives:
o Implementability -The implementability of a particular remedial
alternative can be measured in terms of the relative ease of
installation and the time required to achieve a specified level of
"cleanup" or response. Ease of installation can be measured in terms of
the physical conditions at the site (topography, geology, hydrology)
that influence the ability to build the remedial system.
Time to implement must include provision for pilot testing, availability
of specialized construction equipment, severe weather conditions, and
unanticipated site conditions. Finally, time to achieve beneficial
results is a criterion of implementability. Preference is obviously
given to those technologies that establish containment and control of
onaite and offaite contamination in a minimal amount of time.
o Reliability -The reliability of the remedial alternative is baaed upon
the requirements for operation and maintenance, and the demonstrated
historical performance of the alternative under comparable conditions.
o Performance -The performance of a remedial technology can be expressed
in terms of effectiveness and useful life. Effectiveness is a measure
of the degree to which the alternative is successful in accomplishing
the design objective. Useful life is the length of time that the design
effectiveness can be maintained.
s.2.10.2 Public Health Analysis
The baseline public health evaluation performed under the remedial
investigation constitutes an assessment of the no-action alternative in the
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RI/FS process. The three tasks outlined below, which address the development
and evaluation of additional proposed remedial alternatives, will be
performed under the feasibility study.
Develop Cleanup Criteria
To aid in the design of remedial alternatives, target chemical concentrations
in affected media will be developed based on public health considerations.
Specifically, this will involve determination of the concentrations of
indicator chemicals in environmental media that would be considered to pose a
substantial risk to public health or the environment. Preliminary approaches
for developing criteria and preliminary criteria can be identified/developed
as data becomes available and as the risk assessment is performed.
Detailed Public Health Evaluation Screening of Remedial Alternatives
Subject to the extent of the engineering information provided for each
. alternative, incremental risk reduction factors will be developed for each
alternative to be evaluated in detail so that the relative benefit of
implementing each one can be compared quantitatively.
An assessment of the risk reduction caused by selected remedial alternatives
will be performed. However, it should be noted that the effect of these
remedial actions may not necessarily·be a reduction in risk, particularly
during the remedial action period. For example, removal and offsite disposal
of contaminated materials from the site may create an additional exposure
pathway and resultant risk. Hence, short-term risk resulting from
application of the remedial action itself will also be considered.
5.2.10.3 Environmental Analysis
Each alternative will be evaluated in terms of the extent to which it will
mitigate damage to the environment in comparison to the other remedial
alternatives. Specific considerations to be used in the assessment will be
different for source control alternatives and offsite alternatives.
Each alternative will be evaluated to determine the following:
o Adverse Impacts
A substantial increase in airborne emissions,
A new discharge to surface or ground water,
An increase in the discharge volume of a pollutant from existing
sources or a new facility to receiving waters,
Known or expected significant adverse effects on environmental media
or human use of environmental resources, and
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Known or expected direct or indirect adverse effects on environmentally
sensitive resources or areas, such as wetlands, aquifer recharge zones,
archaeological and historical sites, or endangered or threatened
species.
o Beneficial Effects
Reduction in the release of contaminants and final environmental
conditions,
Improvement in the biological environment and
Improvement in human use resources.
A summary table will be prepared, consisting of each alternative and the
evaluation criteria. A brief narrative description of the advantages and
disadvantages of each alternative cOnsidered will be prepared.
5.2.10.4 Institutional Effects
Remedial alternatives will be evaluated on the basis of institutional
concerns or factors that may impact implementation. Institutional
requirements such as zoning restrictions, rights-of-way, and compliance with
federal, state and local laws, regulations and policies must be considered.
The following institutional factors will be addressed in the evaluation of
alternatives:
o Onsite Requirements -Permit and regulatory requirements applicable to
onsite remedial activities including current EPA policy and guidance on
compliance of CERCLA actions with other federal, state or local
environmental laws will be considered. Activities must meet RCRA 264
Standards and the technical requirements of applicable state and federal
laws.
o Offsite Requirements -Permit and regulatory requirements applicable to
offsite remedial actions, including EPA ground water protection strategy
plus other state. and local laws, will be considered.
o Worker Safety and Health -Requirements and policies, such as OSHA
standards, for protecting the safety and health of onsite workers and
the local populace during alternative implementation will be reviewed.
o The National Environmental Policy Act (NEPA) -Procedures and
requirements will be reviewed to ensure Superfund remedial actions
achieve functional equivalency with NEPA actions.
o Community Relations -Policy recommendations and requirements for
operating a community relations program at a Superfund site will be
reviewed.
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o Coordination With other Agencies -Procedures involving the Department
of Health and Human Services, the Army Corpe of Engineers, the u.s.
Geological Survey, the Department of Interior, Department of
Transportation, Department of Labor, and other governmental authorities
will be reviewed.
5.2.10.5 Coat Analysis
The coat of each remedial action alternative remaining after initial
screening will be evaluated. Each phase or segment of the alternative will
be considered as to cost and non-cost (i.e., loss of natural resources)
criteria. The cost of each alternative will be presented as a present worth
coat and will include the total coat of implementing the alternative and the
annual operating and maintenance costs. A distribution of costs over time
will also be provided. A table showing coat information for each alternative
will be prepared.
In developing detailed coat estimates, the following steps will be taken:
o Estimation of Coate -Capital and annual operating coats for remedial
alternatives will be determined.
o Coat Analysis -Estimated coats will be used to calculate the stream of
payments and present worth for each remedial alternative.
o Sensitivity Analysis -Rieke and uncertainties in coat estimates will be
evaluated. Coat estimates should be within +SO and -50 percent of the
actual coat.
5.2.10.6 Comparison of Alternatives
once the initial list of remedial alternatives has been evaluated, a final
comparative analysis of the acceptable remedial alternatives will be
performed. The specific attributes considered in this comparative evaluation
will· include the following:
o Technical considerations
o Public health considerations
o Environmental considerations
o Institutional considerations
o Incremental benefit/cost analysis
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The remaining acceptable remedial alternatives will be evaluated according to
the previously listed considerations. This preliminary screening will be
accompanied by a series of presentations containing the information on each
of the comparative evaluation considerations.
The acceptable remedial alternatives will.then be ranked according tc the
individual attributes previously identified. These individual rankings can
be applied by the regulatory agencies to assist in selecting the most
cost-effective, technically feasible, and environmentally sound remedial
alternative for the Carolina Transformer Site.
5.2.10.7 Technical/Financial Management
Refer to section 5.2.1.10.
5.2.10.8 Quality Assurance/Quality Control
Refer to section s.2.1.11.
5.2.11 FEASIBILITY STUDY REPORTS
The purpose of this task is to describe the feasibility study and present
results of the analysis.
5.2.11.1 Draft Feasibility Study
A preliminary draft
results of Sections
Technical Screening
feasibility study report
Treatability Study/Pilot
and Remedial Alternative
will be prepared presenting the
Testing, Remedial Alternative
Evaluation.
Subsequently, review comments from EPA and other regulatory agencies and the
State will be incorporated into a second draft, which will present results of
the RI/FS to the public.
5.2.11.2 Public Meeting
Upon review of the draft report, a public meeting will be held to present the
results of t~e study and to identify public health and community issues.
5.2.11.3 Final Feasibility Study
Comments and questions raised during the public meetings will be addressed
during development of the final feasibility study. This revised report will
be submitted to the individual regulatory agencies.
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5.2.11.4 Technical/Financial Management
Refer to Section 5.2.1.10.
5. 2 .11. 5 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
5.2.12 POST-RI/FS SUPPORT
This task includes all activities occurring after release of the feasibility
study to the public. Some or all of tho following subtasks may be performed.
5.2.12.l Conceptual Design Report
The conceptual design subtask includes those activities that are necessary to
support EPA in initiating implementation of the specified remedial
alternative for the Carolina Transformer Site. The conceptual design will
include the engineering approach and address special implementation
requirements, institutional requirements, equipment and personnel
requirements, preliminary design criteria, preliminary site and facility
layouts, and operation and maintenance requirements.
A preliminary remedial schedule will be developed for the individual
activities included in the proposed remedial alternative. In addition, a
preliminary specifications outline forthe various activities conducted
during implementation of the proposed remedial alternative will be developed,
together with a conceptual cost estimate. Consideration will be given to
both capital and annual operating costs.
5.2.12.2 Public Meetings
If additional public meetings are deemed necessary after the initial public
meeting concerning the draft feasibility study, additional public meetings
will be scheduled. Extra public meetings may be necessary to present
additional facts or to allay fears of the local populace.
5.2.12.3 Responsiveness Summary
This subtask _involves summarizing public comments on the draft feasibility
study report-·and responses to these comments. The responsiveness summary is
included as an appendix in the final feasibility study report.
5.2.12.4 ROD Preparation/Briefings
The purpose of this subtask is to conduct PRP negotiation and preparation of
the Record of Decision (ROD).
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5.2.12.5 Technical/Financial Management
Refer to Section 5.2.1.10.
5.2.12.6 Quality Assurance/Quality Control
Refer to Section 5.2.1.11.
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