NCD982096653_20040927_Ram Leather Care Site_FRBCERCLA ROD_Record of Decision-OCR

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NCDE_N_R
COPY
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director Division of Waste Manage~ent Michael F. Easley, Governor
27 September 2004
Ms. Beverly Hudson
Superfund Branch, Waste Management Division
US EPA Region IV
61 Forsyth Street. SW
Atlanta, Georgia 30303
SUBJECT: Concurrence with Interim Record of Decision
Ram Leather Care Site
Charlotte, Mecklenburg County
Dear Ms. Hudson:
William G. Ross Jr, Secretary
The State of North Carolina has reviewed the Interim Record of Decision (ROD) received by the
Division on 27 September 2004 for the Ram Leather Care Site and concurs with the selected remedy,
subject to the following conditions: · I .
1. State concurrence on the ROD for this site is based solely on the information contained in
the ROD received by the State on 27 September 2004. Should the State receive new or
additional information which significantly affectk the conclusions or amended remedy
contained in the ROD, it may modify or withdra(v this concurrence with written notice to
EPA Region IV. I
2. State concurrence on this ROD in no way binds the State to concur in future decisions or
commits the State to participate, financially or otherwise, in the clean up of the site. The
State reserves the right to review, overview comrilent, and make independent assessment
of all future work relating to this site. I .
3. If, after remediation is complete, the total residual risk level exceeds 10 .. , the State may
require deed recordation/restriction to document 1the presence of residual contamination
and possibly limit future use of the property as specified in NCGS 130A-3l0.8
The State of North Carolina appreciates the opportunity tJ comment on the ROD and looks
forward to working with EPA on the final remedy for the subject site. If you have any questions or
comments, please call me at 919 733-2801, extension 278.
I v-,,,,,,,___~
Dave Lown, Head
Rerilediation Branch
Sup~rfund Section
cc: Jack Butler, Chief NC Superfund Section
Ntle Testerman, NC Superfuni:I
1646 Mail cierv1ce Center, Raleigh, North Carolina 27699-1646
I Phone [phone] I FAX [phone] I Internet http //wastenotnc org
An Equal Opportunity I Affirmative Action Employer-Printed o~ Dual Purpose Recycled Paper
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I
INTERIM RECORD OFI DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RAM LEATHER CARE SITE
CHARLOTTE, MECKLENBURG couJTY, NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTE€TION AGENCY
REGION 4 I
ATLANTA, GEORGIA
SEPTEMBER 2004
• •
DECLARATION FOR THE INTERIM RECORD OF DECISION
SITE NAME AND LOCATION
Ram Leather Care Site
Charlotte, Mecklenburg County, North Carolina
EPA Site Identification Number is NCD982096653 (Interim Action)
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Interim Remedy for the Ram Leather Care Site which was chosen in
accordance with the Comprehensive Environmental Response, :compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and,
to the extent practicable, the National Contingency Plan (NCP)1
• This decision is based on the
Administrative Record for the Site.
The State of North Carolina concurs with the Interim Remedy.
ASSESSMENT OF THE SITE
The response action selected in this Interim Record of Decision (ROD) is necessary to protect the public
' health or welfare and the environment from actual or threatened releases of hazardous substances to the
environment. Such release or threat of release may present imrilinent and substantial endangerment to
public health, welfare, or the environment.
DESCRIPTION OF THE INTERIM REMEDY
The Interim Remedy addresses contaminated groundwater and soils at the site. The cleanup strategies
will address threats removal of principal threats. The major c01hponents of the interim remedy include:
Groundwater
Pumping groundwater from existing on-site well to an on-site wastewater treatment system, and
I
subsequently discharge to surface water. Pumping may be continuous or pulsed to allow equilibration of
contaminants with the groundwater. Contaminants will be rem6ved from groundwater via air stripping,
the use of granular activated carbon (GAC), or chemical/ultraviblct (UV) radiation. Treatability studies
will ensure that the selected treatment system will remediate gr6undwater contaminant concentrations to
meet remediation goals. Groundwater monitoring will be requiied.
Soil
Contaminated soil will be excavated and transported off-site to~ Resource Conservation and Recovery
Act (RCRA) Subtitle C or D landfill. Water will be used to minimize fugitive dust emissions during soil
excavation, transport, and handling. After removal of all applic~ble contaminated soils, the site will be
backfilled with clean soil and vegetation planted.
Ram Leather Care Superfund Site II
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STATUTORY DETERMINATIONS
The Interim Remedy is protective of human health and the environment, complies with federal and staie
_ requirements that are applicable or relevant and appropriate to\the remedial action is cost effective. and
uultzes permanent solutions and alternative treatment (onesource recovery) technologies to the ·
maximum extent practicable. For soil and groundwater, this r~medy satisfies the stamtory preference for
treatment_as a principal element of the remedy (i.e .. it reduces ,the toxicity, mobility, or volume of
hazardous substances as a principal element through treatment). Because the interim remedy will result
in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for
unrestricted exposure, a statutory·review will be conducted within five years after commencement of the . ' remedial action to ensure that the remedy is, or will be, protective of human health and the environment.
DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary Section of this ROD. Additional
information can be found in the Administrative Record file for this Site. ·
•
•
•
•
•
Chemicals of concern and their respective concentrations (i<Xppendix B) .
Baseline risk represented by the chemicals of concern (Appendix B)
Cleanup levels established for chemicals of concern and the basis for these levels (Appendix B)
How source materials constituting principal threats are addressed (page 11-1)
•
Curre.nt and reasonably anticipated future land use assump/ions and current and potential future
benefi"ial uses of groundwater used in the Baseline Risk A:ssessment ·and ROD (page 6-1)
Estimated capital, annual operation and maintenance (O&N-1), and total. present worth costs, discount
rate, and the number of years over which the remedy cost e1stimates are projected (pages 9-1 to 9-3) . . • Key factors ,hat led to selecting the remedy (pages 10-1)
AUTHORIZING SIGNATURE
d/~,~
· Winston A. Smith. Director
Waste Management Division
U.S. Environmental Protection Agency, Region 4
Ram Leamer Care. Suoorlund SIie
;?---2? -"-rJY
Date
111
• •
TABLE OF CONTENTS
Decision Summary
Section 1
Section 2
Section 3
Site Name, Location, and Brief Description ............................... 1-1
Site History and Enforcement Activities ... 1 ............................... 2-1
2.1 Operational History ................. J ...................... : ........ 2-1
2.2 Enforcement History .................. 1 ...............•••.•••••••..... 2-1
2.3 Investigation History ................ J ............................... 2-3
Community Participation ............................................... 3-1
Section 4 Scope and Role of Response Action ...................................... 4-1
Section 5
Section 6
Section 7
Summary of Site Characteristics ........................................ 5-1
5.1 Physical Characteristics of the Site ..... ·, ............................... 5-1
5.1.1 Climate ..................................................... 5-l
5.1.2 Site Geology ................................................ 5-1
5.1.3 Site Hydrogeology ............................................ 5-2
5.2 Identification of Exposure Pathways .................................... 5-2
5.2.1 Conceptual Site Model ....................................... , 5-2
5.3 Remedial Investigation (Waste Categories) .... · ........................... 5-3
5.4 Previous Investigations ............................................... 5-4
5.4.1 Initial Studies: 1991 ........................................... 5-4
5.4.2
5.4.3
5.4.4
5.4.5
Site·Owner Investigation: 199 I .................................. 5-4
EPA Emergency Response and Rernoval Branch Investigation ......... 5-5 ' North Carolina Superfund Section Investigation: 1995 ............... 5-5
I EPA Emergency Response and Removal Branch Follow-up
Investigation: 1997 .............. \ ............................... 5-6
5.4.6 EPA Remedial lnvestrgatron: (Phase I) ............................ 5-6
5.4.7 Study Design ................. 1 ............••...••••••••...... 5-6
5.4.8 Conclusions .................. 1 ..............•.•••••••••...... 5-6
5.5 Summary of Groundwater Remedial Investihtion (Phase Il) ................. 5-7
5.5.1 Nature and Extent of Contamination ..... : ........................ 5-7
5.5.2 Area of Contamination Proposed fol Interim Action ................. 5-8
5.5.3 Contaminant Fate and Transport .. l .............................. 5-8
5.5.4 Contaminant Migration ......... ! .............................. 5-9
Current and Potential Future Land and ReJource Use ..................... 6-I
6. I Land Uses .......................... ! .............................. 6-1
6.2 AreaWaterUse ..................... ! ............................. -.6-1
Summary of Site Risks .................. I .......... · .................... 7-1
7.1 Human Health Risk Assessment ......... ! .............................. 7-1
7.2 Hazard Identification ................. 1 .......................••..... 7-1
7 .3 Ex po sure Assessment ................. ! : ............................. 7-1
7.4 Toxicity Assessment ................... 1 ...• , ...................•.... , 7-1
7.5 Risk Characterization .................. 1 •..•.•••••.................•.. 7-2
Ram Leather Care Superfund Site IV
• • Interim Record of Decision Table of Contents
7.5.1 Summary of Risks Associated with\ the Surface Soil ................. 7-2
7.5.2 Summary of Risks Associated withl Groundwater .................... 7-3
7.6 Uncertainty Analysis ................. 1 ............................... 7-3
7.7 Uncertainties Related to Exposure Assess,~cnt ............................ 7-3
7.8 Uncertainties Related to Toxicity Informadon ............................. 7-4
7.9 Uncertainties Related to Groundwater Dad ............................... 7-4
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Section 8
Section 9
7.10 Uncertainties Related to Incomplete Site Characterization ................... 7-4
7.11 Ecological Risk Assessment ........... ) ............................... 7-4
Remedial Action Objectives .............. 1 ............................... 8-1
Description of Alternatives ............... 1 ............................... 9-1
9.1 Description of Grnundwater Alternatives ·I· .............................. 9-1
9.1.1 Alternative GI. No Action ..................................... 9-1
9.1.2 Alternative 02: Pump and Treat with Biological Treatment and
Groundwater Monitoring ....... ,I. .......................... · .... 9-1
9.1.3 Alternative 03: Pump and Treat with Physical/Chemical
Treatment and Groundwater Monitbring ........................... 9-1
9.2 Description of Soil Alternatives ........................................ 9-2
9.2.1 Alternative SI: No Action ..................................... 9-2
9.2.2 Alternative S2: On-Site Treatment with Soil Vapor Extraction ......... 9-2
9.2.3 Alternative S3: Excavation, Off-Sit~ Transportation and ·
Disposal at Subtitle C or D Landfill' .............................. 9-2
Section 10 Comparative Analysis of Alternatives ................................... I 0-1
Section 11 Principal Threat Waste ................................................ 11-1
Section 12 The Selected Interim Remedy .......................................... 12-1
12.1 Alternative S2: Excavation, Off-site Transportation, and Disposal at
Subtitle D Landfill ................... \ .............................. 12-1
12.2 Alternative 03: · Pump and Treat with Physical/chemical Treatment and
Groundwater Monitoring .............. 1 ....••••••••••..•............. 12-1
12.3 Summary of Estimated Interim Remedy Coit for Soils and Groundwater ....... 12-1
Section 13 ·statutory Determinations ................ 1 .............................. 13-1
13.1 Protection of Human Health and the Environriient .......................... 13-1
13.2 Compliance with Applicable or Relevant and \Appropriate Requirements ........ 13-1
I Section 14 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-1
Appendices
Appendix A: Figures
Appendix B: Data Tables
Appendix C: Proposed Plan Fact Sheet
Appendix D: Responsiveness Summary
Appendix E: State Concurrence Letter
Ram Leather Care Superfund Site V
1-1
5-1
5-2
5-3
5-4
5-5
5-6
5-7
5-8
5-9
5-10
5-11
2-1
2-2
5-1
5-2
5-3
5-4
5-5
7-1
7-2
7-3
7-4
7-5
7-6
7-7
7-8
7-9
7-10
8-1
10-1
10-2
12-1-12-3
13-1-13-5
13-6-13-8
• •
LIST OF FIGURES
(Al/figures are located in Ap),endix A)
Site Location Map
Graphic Conceptual Site Model
Site Feature Map
Photograph of the Drum Storage Area
Photograph of an Uncovered Hole in Drum Storage Area
Private Wells in Site Vicinity I
Bold Research Labs Sample ,Locations
EPA Technical Assistance Team Sample Locations
Remedial Investigation On-site Locations, 1999 I
Remedial Investigation On-site and Off-site Sample Locations, 1999
' Consolidated Results of Five Groundwater Investigations
Approximate Extent of Soil to be Addressed
LIST OF TABLES
(All tables are located in Ap1Jendix B)
Soil Samples Collected by Ram Leather Care, 1991
1
1
Soil Samples Collected by EPA, March 1994
Bold Research Labs Groundwater Sample Results, 1991
Bold Research Labs Soil Sample Results, 1991 I
1994 Technical Assistance Team Soil Sample Results
1994 Technical Assistance Team Groundwater sa/nple Results
1999 EPA Remedial Investigation Volatile Organi6 Compound Analytical Results
Exposure Point Concentrations Summary-Currerit/Future Reasonable Maximum Exposure
to Soil I
Exposure Point Concentrations Summary-Current Reasonable Maximum Exposure to
Groundwater at Private Well 0011 I
Exposure Point Concentrations Summary-Current Reasonable Maximum Exposure to
Groundwater at Private Well 0113 I
Exposure Point Concentrations Summary-Current Reasonable Maximum Exposure to
Groundwater at Private Well 089 · I
Exposure Point Concentrations Summary-Future Reasonable Maximum Exposure to
Groundwater
Selection of Exposure Pathways
Cancer Toxicity Data-Oral/Dermal
Cancer Toxicity Data.:_lnhalation .
Non-Cancer Toxicity Data-Inhalation
Non-Cancer Toxicity Data-Oral/Dermal
Risk-Based Remedial Goal Options and ARARs for Groundwater
Summary of Soil Alternatives Evaluation
Summary of Groundwater Alternatives Evaluation
Detailed Interim Remedy Cost Estimates
Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
Summary of Potential State Applicable or Relevant! and Appropriate Requirements
Ram Leather Care Superfund Site VI
• •
LIST OF ACRONYMS AND ABBREVIATIONS
amsl
ARAR
bgs
bis
BNA
BTEX
COM
CERCLA
coc
COPC
CSF
DCA
OCE
ONAPL
EPA
FFS
GAC
!PE
kg
L
LOAEL
MCDEP
MCL
µg
mg
MTBE
Mff/V
NCDEHNR
NCP
NOAEL
NOV
NPL
O&M
PCB
PCE-
ppb
ppm
PVC
RAO
RCRA
RfD
RGO
RI
ROD
SARA
SESD
Ram Leather Care Superfund S1/e
above mean sea level
applicable or relevant and appropriate requirement
below ground surface
below land surface
base/neutral/acid extractable compounds (semivolatiles)
I benzene, toluene, ethylbenzene, ana xylene
COM Federal Programs Corporati6n
Comprehensive Environmental Relponse, Compensation, and Liability Act
of 1980
contaminant of concern
chemical of potential concern
cancer slope factor
dichloroethane
dichloroethene
dense nonaqueous-phase liquid
United States Environmental Protection Agency
Focused Feasibility Study
granular activated carbon
iso-propylethene
kilogram
liter
I owest -observed-adverse-effect -level
Mecklenburg County Department cif Environmental Protection
maximum contaminant level
microgram
milligram
methyl tertiary butyl ether
mobility/toxicity/volume
North Carolina Department of Environment, Health, and Natural Resources
National Contingency Plan
no-observed-adverse-effect-level
Notice of Violation
National Priorities List
operation and maintenance
polychlorinated biphenyl
tetrachloroethene
parts per billion
parts per million
polyvinyl chloride
Remedial Action Objective
Resource Conservation and Recovery Act
reference dose value
Remedial Goal Option
Remedial Investigation
Record of Decision
Superfund Amendments and Reautliorization Act of 1986
Science and Ecosystem Support DiJision
VII
Interim Record of Decision
SSL
svoc
TAT
TCA
TCE
TCLP
USGS
UV
voe
Ram Leather Care S11perf11nd SJ/e
•
soil screening level
semivolatile organic compound
Technical Assistance Team
trichloroethane
trichloroethene
toxicity characteristic leachate procedure
U.S. Geological Survey
ultraviolet
volatile organic compound
• List of Acronyms and Abbreviations
VIII
• • Interim Record of Decision
Decision Summary
• •
SECTION 1
SITE NAME, LOCATION, AND BRIEF DESCRIPTION
I The United Stales Environmental Protection Agency's (EPA's) Identification Number for the Ram
Leather Care Site (the "Site") is NCD058754789. The Site is i'ocaled at 15100 Albemarle Road
(Roule 24/27) in a rural area of eastern Mecklenburg County, ~orth Carolina, just west of the Cabarrus
County line. The site is located at 35° 13' 41" north latitude and 80' 36' 24.50" west longitude. The site
is located approximately four miles from the Charlotte city boJndary.
The lead agency for the Comprehensive Environmental RespoAse, Compensation, and Liability Act of
' 1980 (CERCLA) regulatory response al the Site is EPA. The !'iorlh Carolina Department of
Environment, Health, and Natural Resources (NCDEHNR) is the support agency.
Ram Leather Care restored leather goods and operated as a drylcleaning facility. Chlorinated
hydrocarbon chemicals [primarily tetrachloroethene (PCE) and petroleum hydrocarbons (mineral spirits)]
were used in the cleaning process. The dry cleaning facility is bo longer in operation and the site is
currently operating as a weekend flea market. The site and the[surrounding property is illustrated in
Figure 1-1. The site is surrounded by residential properly. To the south is a 14-acre privately owned ' parcel. A small fishing pond is located on the 14-acre parcel. To the east is the 8-acre privately owned
parcel. To the north is another privately owned parcel. To the[west is the 18-acre privately owned
parcel. A gravel road running southeast from the Ram Leather Care driveway provides access to two
residences.
Ram Lea/lier Care $(Jperfund Site 1-1
• •
SECTION2
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 OPERATIONAL HISTORY
The Ram Leather Care facility operated from 1977 to 1993. ·The building was constructed in I 967 and ' housed a construction business owned by Mr. Worley until 1977. On May 6, 1987, Ram Leather Care ' submitted its first Notification of Hazardous Waste Activity. Ram Leather Care reported that it was a ' generator of less than 1,000 kilograms (kg)/month of DOOi RORA wastes (as defined in the Resource
I Conservation and Recovery Act, 40 CFR 261.21). On June 8, ,t987, EPA assigned the number
NCO 982 096 653 to Ram Leather Care as a small quantity gerierator.
On April 6, 1991, during a complaint investigation of a demolilion landfill on adjacent property,
Mecklenburg County Department of Environmental Protectionj(MCDEP) inspector discovered illegal
open burning at the Ram Leather Care site. The facility operator was burning filters containing PCE.
The facility was instructed to stop and complied. MCDEP issiled a Notice of Violation (NOV) for this
burning. I
On April 29, 1991, the NCDEHNR inspector visited the site. The inspector noted that the last . I documented disposal of DOOi waste petroleum naphtha was on February 12, 1988. Mr. Worley stated
' that the Dry Cleaners Trade Association had sent information that certain petroleum-based dry cleaning • I solvents were no longer deemed hazardous waste and that he had assumed that his waste was no longer
hazardous. The inspector discovered a 250-gallon above-grourid storage tank of D00 I waste mineral
spirits and 49 drums of liquid waste inan outside waste storagq area. Bungs were open, allowing
rainwater to enter the drums and waste to overflow. Logs and drum markings were not maint_ained. The
drums were standing in liquid. A composite sample of drum c6ntents and a surface soil sample were
taken on May 2, 1991.
The NCDEHNR was notified April 30, 1991, of a boiler blow-off in the storage area. A permit had not
been issued for the site, making this an illegal discharge. The tirea had been recently graded to allow
surface water runoff to flow toward Albemarle Road. A drinkihg water well was noted within 50 feet of
the storage area and was sampled on May 6, 1991,by MCDEPJ Due to contamination found in the well,
Ram Leather Care was advised to discontinue using the well fo~ drinking. On May 13, 1991, all off-site
drinking water wells within½ mile were sampled. Two privatd residential wells were found to be
contaminated. I
On June 5, 1991, an NCDEHNR inspector visited the Ram Leather Care site lo provide instructions to
tv\r. Worley. While there, Ram Leather Care requested a change i_n classification under RCRA because
the 49 drums of D00 I hazardous waste were in excess of 6,0001kg, exceeding small quantity generator
status. Mr. Worley stated that PCE filters were stored in a dumpster prior to disposal in a landfill.
Stored hazardous wastes were shipped off-site on June 14, 1991. Ram Leather Care was reclassified as a
Large Quantity generator on June 17, 1991.
2.2 ENFORCEMENT HISTORY
On June 5, 1991, an Imminent Action NOV Docket #91-264 was issued to Ram Leather Care for Storage
and Disposal of Hazardous Waste. The compliance schedule re1quircd submittal of a comprehensive
Ram Leather Care Superfund Site 2-1
• • Interim Record of Decision Site History and Enforcement Activities
I sampling and analysis report by July 26, 1991, soil removal with post-excavation samples by
I September I, 1991, and removal of all hazardous wastes by September I, 1991.
On July 3, 1991, an NOV was issued by the NCDEHNR for vibiation of groundwater quality standards.
The NOV required remediation of contaminated soil and grouridwater and provision of an alternate water ' supply to affected well owners (Parnell and Beaver). On July 26, 1991, the NCDEHNR held in abeyance
the order to remediate the site and deferred lead agency status lo the North Carolina Hazardous Waste
Section. The NOY still required provision of alternate water sl1pply to affected well owners.
I
On August 2, 1991, Ram Leather Care responded to the NCDEHNR by letter and said that the two ' private residences had been provided with bottled water. On November 5, 1991, Ram Leather Care ' submitted a Technical and Field Data Report to the NCDEHNR.
On January 24, 1992, a Compliance Order with ;dministratiJ Penalty, Docket #92-068 was issued by ' the NCDEHNR. This NOV stated that between 1977 and 1984, wastes generated from the use of ·
chlorinated hydrocarbons were disposed of in a metal dumpsteL After 1984, 55-gallon drums were used
to store the solvents, which were then transported off-site for rbcycling. Between 1984 and 1988, wastes
were also stored in an above-ground waste tank supported by al concrete pad on the west side of the
building. The NOY cited Ram Leather Care for storage of hazardous waste on-site for longer than
90 days, improper or lack of marking on hazardous waste contriiners, failure to file an annual report,
discharge of DOOi and F002 hazardous wastes onto the ground and into the groundwater, and failure to
submit a permit application. The NOY imposed a penalty.
On February 26, 1992, Ram Leather Care filed a petition for an Administrative hearing to contest the
order. On April 29, 1992, NOV Docket #92-232 was issued toiRam Leather Care by the NCDEHNR for
failure to submit an annual report. On May 12, 1992, Ram Leather Care responded with the annual .
report and contested the NOV. (A small quantity generator is ,lot required to file an annual report
whereas a large quantity generator is required.) Ram Leather Gare stated that generator status was based
on amount generated, not stored. The annual report stated that 1the following quantities of waste were
generated and shipped off-site in 1991:
Perchloroethylene/ignitable, D039
Filters containing waste perchloroethylcne/ignitable, D039
Filters containing waste mineral spirits/ignitable, DOOi
Waste mineral spirits/ignitable, D00 I
2,900 kg
1,268 kg
700 kg
3,315 kg
On July 17, 1992, Ram Leather Care provided a Soil Vapor Extraction Proposal to the NCDEHNR
Attorney General's Office. A memo dated July 29, 1992, from 1the NCDEHNR Inspector to NC Assistant
Attorney General, stated that Ram Leather Care was not in com1pliance with NOV Docket #92-264. This
memo also stated that Ram Leather Care had made little attempt to meet the requirements of the Order
which required removal of on-site contaminated soil.
On January 30, 1992, Mecklenburg County again sampled area
1
wells. NCDEHNR communicated to
Mr. Worley on March 16, 1992, that he was still required to provide alternate water supply to residents
with contaminated wells. It was suggested that Mr. Worley con1sider a point-of-entry filter system. On_
July 15, 1992, Ram Leather Care sampled three water supply whlls, including the new on-site well. An
August I 0, 1992, letter states that Ram Leather Care continues io supply alternate water supplies to both
residences. On August 26, 1992, Mecklenburg County again sa1mpled area wells and determined that an
' additional residential well was also contaminated. On March 18, 1993, Ram Leather Care filed for
' Chapter 7 Voluntary Bankruptcy. On April 19, 1993, NCDEHNR requested that the Commerce Finance
Center pursue funding to provide a permanent alternate water sJpply ..
Ram Leather Care Superlund S1/e 2-2
• • Interim Record of Decision Site History and Enforcement Activities
Additional well samples taken by Mecklenburg County on Junl 22, 1993, showed that the well at
15205 Albemarle Road was contaminated. Subsequent tests hlve shown the well to be clean. On
September 8, 1993, NC Division of Solid Waste Management,IWaste Management Branch, referred the
site to the North Carolina Superfund Section for possible immediate action to provide a reliable
I alternative water supply to the residents. A September 28, 1993, inspection report stated that the Ram
Leather Care facility was in Chapter 7 bankruptcy and had bech unable to.comply with Compliance
I Order with Administrative Penalty Docket #92-068 in full. Alternative water was still being provided to
area residents who would accept it, but site cleanup had not pr6gressed.
I
On February 16, 1994, the NCDEHNR requested that EPA evaluate Ram Leather Care for possible
removal action and on March 16, 1994, EPA sampled on-site sbil and neighboring wells. EPA ' determined that wells surrounding the site were below removal action levels.and assigned the site a low
priority for removal action.
Between the EPA removal evaluation and September 26, 1995, a new deep well was installed at the
residence located across the street from the facility. The resid6nt had discontinued using bottled water
and had resumed drinking the groundwater. The new well wasi sampled during the NCDEHNR Site
Inspection on September 26, 1995. The well showed 204 parts1per billion (ppb) of PCE, which was
much higher than any previous sampling results from that residence. The MCDEP also sampled the well
and found a high level of PCE. The NCDEHNR again requcstJd an EPA removal action. EPA sampled
the well and determined that it qualified fora high priority rem~val action.
2.3 INVESTIGATION HISTORY
In May 1991, the on-site drinking water well serving 8 to IO employees was sampled by Mecklenburg
County and was contaminated with chlorinated solvents. The Jse of this well was discontinued. Three
neighboring potable wells serving eight residents were later sarhpied by the County and determined to
contain chlorinated solvents. Mecklenburg County sampled th6 potable wells near Ram Leather Care
and did not find additional PCE contamination.
Extensive subsurface soil sampling was conducted by Bold Research Labs, Incorporated (Inc.), for Ram ' Leather Care in 1991; surface soil sampling was conducted by Heritage Environmental Services for Ram
Leather Care in 1991; and EPA conducted surface soil samplin~ in 1994. The sampling events confirmed
the presence of the chlorinated solvents on-site that have been found in neighboring groundwater
drinking water wells in repeated sampling events.
A composite sample of drnm contents and a surface soil sample under the storage area were collected by I
Heritage Environmental Services. Split samples were received by the NCDEHNR on May 2, 1991. The
drum sample was analyzed for total volatile organic contaminarits, base/neutral/acid extractable
compounds [(BNAs) semi volatiles], and flash point. The soil simple was analyzed for toxicity
characteristic leachate procedure (TCLP) and total volatile org,/nic compounds (VOCs) and semivolatile
organic compounds (SVOCs). The only quantifiable result frorh the TCLP analyses was I ppb vinyl
' chloride, but this was not confirmed with replicated analysis. The results of the analyses for total organic
contaminants are shown in Table 2-1. A sample of boiler blowi>ut was collected by the·MCDEP on
May 6, 1991. This sample was analyzed for VOCs. PCE at 77 barts per million (ppm) was detected in
the boiler blowout. Other organics were also detected, but could not be identified due to the high level of
PCE.
From July to October 1991, a site investigation was conducted l:iy Bold Research Labs, Inc., for Ram
Leather Care in order to comply with NOV Docket #91-264. Stlmples were analyzed for VOCs,
Ram Leather Care Superfund S1/e 2-3
• • Interim Record of Decision Site History and Enforcement Activities
I including PCE, vinyl chloride, and the petroleum constituepts !PE (iso-propylethene), MTBE (methyl
tertiary butyl ether), and BTEX (benzene, toluene, ethylbenzerie, and xylene). Soil samples were also
tested for mineral spirits.
In response to a request by the NCDEHNR, EPA performed on-site soil and off-site drinking water well
sampling in 1994 to determine if a removal action was warrantbd. The soil samples were analyzed for ' VOCs, SVOCs, and metals. Surface soil showed PCE and bis~2-ethyl hexyl)phthalate in RL-SS-001
(near the former drum storage area) and RL-SS-004 (in the surface water runoff pathway just before the
culvert) sample locations. RL-SS-004 also showed 3,4-methylphenol. Bis(2-ethyl hexyl)phthalate was . .
also detected in sample location RL-SS-002 (area of stained soil along the surface water runoff pathway).
The level of soil contamination did not qualify the site for a high priority removal action of on-site soil
by EPA. As previously discussed, the potable well sampling results did not qualify for high priority
removal. _ I
The 1996 NCDEHNR Combi11ed Prelimi11wy Assessme11r/Sire l11spectio11 Report estimated that
significant amounts of contaminated soil remain on the site. The report concluded that soil containing
chlorinated solvents and phthalates existed in the former dumpkter area, the septic field, and along the
surface water runoff pathway. The report stated that a conservhtive estimate of 147 cubic yards of
contaminated soil (surface area 350 square feet) was present ori site. PCE, trichloroethene (TCE),
' . I, 1-dichloroethene (DCE), and vinyl chloride, known degradation products of PCE, are among the
chlorinated solvents that have been detected in the soil. There has been no removal of contaminated soil
from the site. The drums and the contents of the 250-gallon abbve-ground tank containing hazardous ' wastes have been removed from the site. The 1996 North Carolina Superfund report also concluded that
there had been no observed release of site contaminants to surfhce water.
Past analytical results are summarized in Tables 2-1 and 2-2.
EPA conducted the Remedial Investigation (RI) in two parts. In 1999, EPA's Science and Ecosystem
Support Division (SESD) in Athens, Georgia, ~onducted an RI.\ The purpose of the RI was to assess the
areal and vertical extent of contaminated soil and groundwater at the Site and to determine whether
additional potable wells adjacent to the Site were contaminated!. In 2000, EPA tasked COM Federal
Programs Corporation (COM) to undertake additional groundw~ter studies. The main objectives of the
additional studies were to determine the nature of the fracture z~nes in the area and the extent of
contamination in the fractured bedrock aquifer.
On May 14, 2003, EPA's Emergency Response and Removal Branch initiated a removal action at the
Ram Leather Care Site. EPA will install a water line from the ihtersection of Flow~s Store Road and
' State Route 24/27 to residences on Albemarle Road during the Fall of 2004.
The Site was placed on the National Priorities List (NPL) on Sjptember 29, 2003. The NPL is EPA's list
of nationwide priority hazardous waste sites which are eligible for federal cleanup monies from the
Superfund Trust Fund.
Ram Leather Care Superfund Site 2-4
• •
SECTION 3
COMMUNITY PARTICIPATION
This section summarizes the community relations activities performed by EPA and NCDEHNR during
the investigation and interim remedy selection process. EPA ahd NCDEHNR developed a community
relations plan for the site to promote public awareness of clean1up activities and investigations and to
promote public involvement in the decision-making process. Gommunity participation activities included
I community forums, fact sheets, public meetings, and public notices.
The focused feasibility· study (FFS) report and the interim proJosed plan for the Ram Leather Care
Superfund Site were released to the public for comment on July I, 2004. These documents were made
available to the public in both the administrative record and anjinformation repository maintained at the
EPA Superfund Record Center in Region 4 and at the Mint Hill Branch Library. In addition, over 200
copies of the Interim Proposed Plan were mailed to citizens in heighborhoods adjacent to the Site. The
notice of availability of these two documents was published in 1the Charlotte Observer on July 6, 2004. A
public comment period on the documents was held from July 7 to August 7, 2004.
A public meeting was held on July 7, 2004, at the Mint Hill To1wn Hall, Mint Hill, North Carolina. At
this meeting, representatives from EPA, NCDEHNR, Mecklenburg County, and major property owners
answered questions about current conditions at the Site, and thb remedial alternatives under
consideration. A response to the comments received during thi:s period is included in the Responsiveness
Summary, which is part of-this Interim Record of Decision (ROD).
Ram Leatfler Care Superhmd Site . 3-1
• •
SECTION 4
SCOPE AND ROLE OF RES.RONSE ACTION
As with many Superfund sites, the problems at the Ram Leather Care site are complex. As a result, EPA
divided the remedial work into two phases. This ROD addresdes the contaminated soils and the
groundwater as an interim action. This action will be the first hction for the Site. EPA has determined ,
that, because the existing data are not sufficient to determine the likelihood of attaining long-term
objectives (e.g., restoring groundwater) over all portions of th~ plume and site-related contaminants
continue to be found in nearby potable wells, a phased ground<vater response action is appropriate for
this Site. The phased groundwater response action i,ivolves th~ completion of an early or interim action
(documented in an interim ROD) followed by a long-term rembdy (documented in a separate ROD). The
' use of a phased approach allows EPA to mitigate more immediate threats such as reducing further plume
migration, with an interim remedy, while concurrently collecti/1g additional characterization data to
I detennine the likelihood of attaining long-term objectives and to evaluate the viability of monitored
natural attenuation.
Ram Leather Caro Superfund Site 4-1
•
SECTION 5
SUMMARY OF SITE CHARJ\CTERISTICS
5.1 PHYSICAL CHARACTERISTICS OF THE SITE
The total relief on the Site is about 13 feet, ranging fro;,, a basin in the northwest comer at 717.2 feet
above mean sea level (amsl) to the highest point of 730.4 feet rims) in the south. There are two overland
tlow paths for site drainage. The northern pathways flow thro~gh culverts under the railroad tracks and
Route 24/27. This intermittent stream continues for 2,500 feetjuntil it joins a perennial stream. This
perennial stream continues north for 1,000 feet and flows into a pond that is 800 feet long. The outfall
from this pond is an unnamed tributary to Caldwell Creek.
Runoff from the southern portion of this site flows south and enters a pond 1,000 feet to the south. The
pond is 200 feet long. Several springs emerge along the ovcrlind flow pathway and in other areas
between the Site and the pond. The outfall from this pond tloi>s 1,200 feet where it enters a larger pond.
Outfall from this pond enters Wiley Branch which leads to Clehr Creek.
5.1.1 Climate
The area has a mean annual precipitation of 45 inches per year and a mean annual lake evaporation of ' 41 inches per year, resulting in a net precipitation of 4 inches. lfhe two-year, 24-hour rainfall is
3.5 inches. This site is outside the 500-year floodplain.
5.1.2 Site Geology
The soils at the Site arc classified as part of the Georgevillc unit, characterized by a silty clay loam. The ' surface layer is a yellowish red silty clay loam, approximately 5 inches thick. Below this is about 4 feet
of strongly acidic subsoil, the upper part of which is a red silty ~lay. The lower part is a red silty clay
loam. Under the subsoil is a silt loam to approximately 9 feet 8elow land surface (bis). Depth to bedrock
is about 42 feet bis. I
The Site is located in the western edge of the Carolina Slate Belt of North Carolina. Classified as
phyllites, these rocks are very fine in texture. The metavolcanib rock is characterized by interbedded
felsic to mafic tufts and flowrock. The residuum from the fine-grained slate forms the Georgeville series
subsoil mentioned above. I
Rock units in the area have undergone a period of deformation that have produced folding and fractured
planes in the rock, as well as brittle zones where the rock is cru~hed, sheared, or faulted in some manner.
As these rock types become weathered, soil profiles develop thrit are characteristic of the original rock
(also referred to as saprolite). The rocks have been fractured du~ing metamorphic phases and, in some
cases, the fractures have been "resealed" by quartz. As rock wdathers, these quartz fillings are retained
in the soil, indicating that fractures existed in the rock. In addition, remnant fractures can be seen in the
soil profile without quartz.infilling, as indicated by the presenc~ of iron staining along the fracture plane.
The iron staining is a result of groundwater leaching iron from the surrounding material. As groundwater
travels along a fracture plane, the iron is redeposited along the J1ane. Fracture planes can be detected
during drilling as zones of weak-to-incompetent rock that are ncit resistant to the cutting action of the drill
bit. These fracture zones are typically water saturated.
Ram Leather Care Superfund Site 5-1
• • Interim Record of Decision Summary of Site Characteristics
Stratigraphy at the site consists of a saprolite layer, a partiall)1weathered rock zone, and the underlying
fractured crystalline bedrock. The saprolite is clay-rich, residual material derived from in-place
weathering of bedrock. Typically, the saprolite is silty clay nel,r the surface. With increasing depth, the ' amount of silt, fine-grained sand, and gravel tend to increase. Remnant fracture planes with quartz
infilling appear in this layer. The thickness of the saprolite in the vicinity of the Site ranges from 24 to
42 feet. The range is based on soil borings drilled in 1991 that1 showed auger refusal at 24 feet and the
well log for the on-site deep well that showed the depth to bed}ock as approximately 42 feet bis. This is
consistent with the August 1999 drilling in which bedrock wasl encountered at approximately 45 feet bis.
Underlying the saprolite is a partially-weathered rock layer dJived from the weathering of bedrock.
I Partially-weathered rock is composed of saprolite and fragments of weathered bedrock. Grain sizes
range from silts and clays to large boulders of unweathered bedrock. The weathering occurs in bedrock ' zones less resistant to physical and chemical degradation (i.e., fault zones, stress relief fractures, and
mineralogic zones).
5.1.3 Site Hydrogeology
Regionally, the water-bearing units _that underlie the Site repre~ent an aquifer system consisting of
metamorphosed and fractured phyllite rocks of varying proportions and thicknesses. The aquifer system
underlying the Site generally consists of the saprolite/partially-:weathered rock aquifer and the underlying
fractured bedrock aquifer. In the Site area, the water is typically found in the saprolite aquifer and will
generally mimic the overlying land surface. The depth to wate} is approximately 12 feet. . I
Shallow groundwater movement is assumed to somewhat follow the topography. Based on a U.S.
Geological Survey (USGS) topographic map, ground surface al the site slopes to the southeast and the
northwest, creating a groundwater divide (USGS 1980). Howerer, groundwater flow is likely controlled
by the presence of relict fractures present in the saprolite, fractures in the partially-weathered as well as
competent bedrock, and the steep dip of the bedrock units to th~ northwest. Given the complexity of the
bedrock at the site, the direction of groundwater flow depends ~rimarily on fractures, faults, bedding
planes, etc. According to LeGrand and Mundorff ( 1952), mostlof the natural flow in the bedrock system
is probably confined to the upper 30 feet of bedrock where fractures are concentrated, and the overlying
transition zone which apparently has the highest hydraulic conductivity of any part of the hydrogeologic
system.
5.2 IDENTIFICATION OF EXPOSURE PATHWAYS
Exposure pathways are determined in a conceptual site model that incorporates information on the
potential chemical sources, release mechanisms, affected medi), potential exposure pathways, and known
receptors to identify complete exposure pathways. A pathway i1s considered complete if (I) there is a
source or chemical release from a source, (2) there is an exposu1re point where contact can occur, and
(3) there is a route of exposure (i.e., oral, dermal, or inhalation) through which the chemical may be taken
into the body.
5.2.1 Conceptual Site Model
The conceptual site model for this assessment is presented in Figure 5-1. As seen in Figure 5-1 and
discussed in EPA's RI report dated March 14, 2000, contamination at this site occurred as a result of
spills or leaks of dry cleaning solvents. Once released, contamihants impacted the surface soil and the
saprolite/partially-weathered rock aquifer underneath. EPA's irivestigation in 1999 showed that the soil
on-site is contaminated. ,
Ram Leather Care Superfund Site 5-2
• • Interim Record of Decision Summary of Site Characteristics
Fractured bedrock underlies the saprolite. Analysis of rock cores showed a diagonal fracture pattern,
suggesting pathways for dense nonaqueous-phase liquid (DNAPL) and/or dissolved dry cleaning fluids to
migrate downward. The direction of migration is dependent primarily on the actual geometry of the
fracture system, which is not known. Private wells in the area are set in the fractured bedrock.
Contamination has been well documented in three private wells. Additionally, both former drinking
water wells on-site are heavily contaminated.
Based on this understanding of the distribution of contaminants, and the potential for human contact, the
following media/receptors were examined:
(I) Soil-Potential receptors are current and future workers, site visitors/trespassers, and future
residents.
(2) Groundwater-Potential receptors are current area residents who use private wells and future site
residents.
Potentially complete exposure pathways examined in this risk assessment are:
■ incidental ingestion of soil,
• inhalation of particulates released from soil,
• dermal contact with soil,
• ingestion of groundwater, and
• inhalation of volatiles released from groundwater during showering.
5.3 REMEDIAL INVESTIGATION (SOURCE CATEGORIES)
A review of the available file material and an EPA site reconnaissance indicated several source
categories. The areas identified were the septic tank/septic tank drain field,.former dumpster area,
surface water ditch/culvert, and former drum storage area. The Site feature map is illustrated in
Figure 5-2 and a brief description is given below:
• Septic Tank/Septic Tank Drain Field-A subsurface septic tank wastewater system has been in
operation at the site since 1977. The septic tank is located on the north side of the Ram Leather Care
building. Wastewater from the septic tank was pumped to a drain field in the southern portion of the
property. This partially vegetated area is unfenced and accessible to the adjacent residents.
• Fonner Dumpster Area-The former dumpster area (where the filter burning occurred) is located on
the south side of the Ram Leather Care building. This area is currently covered and serves as part of
the gravel parking lot. The wastes generated at the site were placed in the metal dumpster from 1977
until 1984. The dumpster has since been removed.
• Surface Water/Ditch Culvert-Water from the northern portion of the site flows in a ditch and
through culverts under a railroad track and Route 24/27 to an intermittent stream across the street
from the Site. Soil samples were collected from the Site just prior to entering the culvert under the
railroad track. The area was sampled to determine if contamination was leaving the Site via surface
water drainage.
• Former Drum Storage Arca-After 1984, 55-gallon drums were used to store the waste generated at
the site. The former dmm storage area is located next to the western part of the building. Drums
were placed on a cement pad. A grassy area is adjacent to the cement pad. Contamination in this
Ram Leather Care Superfund Site 5-3
• • Interim Record of Decision Summary of Site Characteristics
area is due, in part, to drum leakage and spills. When discovered in 1991, it was noted that the bungs
had been left open allowing rain to enter the drums and overflow. Areas of stained or stressed
vegetation have been observed in the area adjacent to' the drum storage area.
During the April 1999 investigation, a hole (Figures 5-3 and 5-4) was uncovered adjacent to the drum
pad. The hole had been drilled and was approximately 10 inches in diameter. The hole had been drilled
to a depth in excess of IO feet and is currently filled with collapsed material to a depth of 10 feet. The
drilled hole was covered by a 55-gallon drum lid and cement. Air monitoring conducted by EPA at the
top of the hole indicated the presence of organic compounds.
It is not known whether the hole was due to a failed well installation attempt, past sampling activities, or
was used for past dumping of solvents. The hole would have received storm water runoff from the drum
storage area.
5.4 PREVIOUS INVESTIGATIONS
5.4.1 Initial Studies: 1991
A series of investigations took place in May 1991. Shortly after the Site was discovered, the state and the
owner sampled drums and surface soil in the drum storage area. Analyses of composite samples of drum
contents indicated the presence of PCE, toluene, ethyl benzene, xylenes, and phthalates. Soil samples
indicated the presence of phthalates, vinyl chloride, I, 1-DCE, 1,2-DCE, TCE, PCE, and acetone.
Subsequently, the state sampled the boiler blowdown area and found 77 milligrams per kilogram (mg/kg)
of PCE in the soil. The on-site well (depth unknown) was sampled and found to be contaminated
[4,690 micrograms per liter (µg/L) PCE]. The county sampled several off-site wells within one-half mile.
Two wells, Parnell (19 µg/L PCE) and Beaver (3.9 µg/L PCE), were contaminated. Private wells in the
vicinity of the site are shown in Figure 5-5.
5.4.2 Site Owner Investigation: 1991
In July 1991, Bold Research Labs undertook an investigation on behalf of the site owner. The
investigation was designed to identify a possible source of the chlorinated hydrocarbon contamination
and to define the extent of soil and groundwater contamination.
Seventeen soil borings were drilled in the locations shown in Figure 5-6. The investigation showed that
PCE contamination extended to a depth of 24 feet (the deepest sampling point) in Boring I (B-1) near the
former drum storage, to IO feet (the deepest sampling point) in B-10 along the northerly surface water
runoff pathway, and to 20 feet in B-2 near the dumpster. I, I, I-Trichloroethane (TCA) was found in B-2
at 25 feetand in B-3 at 7 feet (the deepest sampling point) near the septic tank drain box. The results are
shown in Table 5-1.
Monitor wells were completed in three of the borings (see Figure 5-6). Groundwater samples were
collected from boreholes B-1 and.B-2 and the three monitor wells. The samples were analyzed for VOCs
and mineral spirits only. PCE was found at 50,060 µg/L in 8-1 (depth 24 feet) near the drum storage
area and boiler blowout. TCA (6,697 µg/L) and TCE (830 µg/L) were found in the same borehole. PCE
was found at 1,201 µg/L in B-2 (depth 25 feet) near the dumpster. Trace quantities ofTCA,
1,2-dichloroethane (1,2-DCA), and TCE were found as well. The results are shown in Table 5-2.
The monitor wells showed only trace contamination. Monitor well MW-I (total depth 32 feet, static
water level 13.68 feet) had I µg/L PCE. Monitor well MW-2 (total depth 32 feet, static water level
Ram Lea/lier Cars Superfund Site 5-4
• • Interim Record of Decision Summary of Site Characteristics
11.98 feet) had no volatile constituents. Monitor well MW-3 (total depth 20 feet, static water level
12.3 feet) had 3 µg/L PCE and no other volatiles. The "new" on-site potable well had 9 µg/L TCE. PCE
was not detected. This well was installed on October 11, 1991. It is 510 feet deep, polyvinyl chloride
(PVC)-cased to 50 feet, and 6 inches in diameter. The reported yield was 6 gallons per minute (Stanley
1998). The results are shown in Table 5-2. ·
Also during this investigation, water samples were collected from boiler blowout, the septic tank, and the
pond south of the Site. In the boiler blowout, the following contaminants were detected: PCE (66 µg/L),
chloroform (9 µg/L), and 1,2-DCA ( I µg/L). The septic tank had 540 µg/L chloroform, 171 µg/L
isopropyl ether, 29 µg/L toluene, 21 µg/L cis-1,3-dichloropropene, and 12 µg/L 1,2-DCA. No PCE was
detected in the septic tank. No contaminants were detected in the pond.
5.4.3 EPA Emergency Response and Removal Branch Investigation
In March 1994, EPA' s Technical Assistance Team (TAT) performed a site investigation to further assess
the extent of surface soil and groundwater contamination on-site and in several private wells in the Site
vicinity. The TAT collected four surface soil samples from'the locations shown in Figure 5-7. The
samples were analyzed for priority pollutant metals, as well as VOCs and SVOCs.
Surface soil samples showed trace quantities.of PCE and bis(2-ethylhexyl)phthalate in SS-01 (near the
former drum storage area). Quantities of PCE and bis(2-ethylhexyl)phthalate were found in SS-04 (in the
surface water runoff pathway just before the culvert). The levels of contamination were not sufficient to
trigger a soil removal action. No inorganics were found at levels of concern. The results are shown in
Table 5-3.
The TAT also collected groundwater samples for VOC analysis from the three existing monitor wells,
the "old" on-site well, and eight off-site private wells. The locations are shown in Figure 5-4.
The "old" on-site well (no longer used) had PCE (2,500 µg/L), TCE (98 µg/L), and cis' 1,2-DCE
(590 µg/L). Three of the eight private wells sampled (Parnell, Beaver, and Glosson) had detectable
quantities of VOCs, but the levels did not exceed EPA's removal action level of 70 ppb. The following
wells had no detectable VOCs: Ivey, Tucker, Watson Body Shop, Harrah, and Scoggins. The results are
shown in Table 5-4.
5.4.4 North Carolina Superfund Section Investigation: 1995
In September 1995, the North Carolina Superfund Section sampled the new Parnell well (250 feet deep,
cased to 41 feet, and installed sometime between the EPA investigation in 1994 and September 1995),
the Tucker well, the "old" on-site Ram Leather Care well, and the Howell facility well (the closest
community well, about 3/4 mile north of the site, serving 430 people). Each well was sampled for VOCs,
SVOCs, and metals. No metals above levels of concern or SVOCs were detected in any of the wells.
The only private or community well that was found to be contaminated was the Parnell well where PCE
(204 µg/L), TCE (8 µg/L), and cis-1,2-DCE (6 µg/L) were. Based on these findings, Mrs. Parnell was
advised to discontinue use of her well for drinking, and the North Carolina Superfund Section requested
that the EPA reevaluate the site for a removal action. The "old" Ram Leather well (depth unknown) had
PCE (1,091 µg/L), cis-1,2-DCE (724 µg/L), and TCE (254 µg/L).
North Carolina also investigated surface water in the north and south drainage pathways for Hazard
Ranking System purposes. Four surface water and sediment sample pairs, two from the northern
drainage route. one from the southern drainage route, and one background sample from a pond west of
the site, were collected. Each sample was analyzed for VOCs, SVOCs, and metals. No VOCs or SVOCs
Ram Leatha, Care Superlund Site 5-5
• • Interim Record of Decision Summary of Site Characteristics
were detected in any surface water sample, except for acetone, which was attributed to laboratory
contamination. Several metals were detected in the surface water and sediment samples; however, the
concentrations were within the typical range found in the area and were not attributed to a release from
the Site.
5.4.5 EPA Emergency Response and Removal Branch Follow-up Investigation: 1997
EPA's Emergency Response and Removal Branch conducted a follow-up investigation to verify the
findings of the State's 1995 investigation. Private wells in the vicinity of the site were sampled. The
results indicated that the levels of contamination exceeded the removal action level. Thus, in February
1997, point-of-entry carbon filtration units were installed on the Parnell, Glosson, and Beaver wells.
Each of these wells have consistently shown chlorinated hydrocarbon contamination.
5.4.6 EPA Remedial Investigation: (Phase I)
In 1999, the EPA SESD in Athens, Georgia, conducted an RI at the site. The goals of the RI included:
■ Assess the areal extent of contaminated surface soil at the site,
■ Assess the areal and vertical extent of contaminated subsurface soil at the site,
■ Determine whether additional potable wells adjacent to the site are contaminated, and
■ Assess the areal and vertical extent of groundwater contamination in the shallow aquifer at the site.
5.4.7 Study Design
The study focused primarily on chlorinated solvents in the soil and groundwater; however, samples for
pesticides, BNAs, full scan VOCs, and metals were also collected. An authoritative sampling design was
chosen. Under an authoritative sampling design, locations are selected where there is a good probability
of finding high levels of contamination. Authoritative samples are not intended to reflect the average
characteristics of the site.
Surface soil, subsurface soil, potable water, and groundwater samples were collected. Grab and
composite samples were collected from locations shown in Figure 5-8 within the Ram Leather Care site
and the adjacent properties. In addition to four potable wells adjacent to the site (Parnell, Glosson,
Beaver, and Ivey), several additional potable wells within approximately one mile of the site were
sampled. These wells were chosen to allow for a representative sampling of the area. Figure 5-9
illustrates soil and water samples that were collected both on the site and in the site vicinity.
5.4.8 Conclusions
Based upon the data collected during the RI, the following conclusions were drawn:
■ Chemicals of Concern-The primary chemicals of concern are chlorinated solvents. BNAs,
polychlorinated biphenyls (PCBs), and metals do not appear to be a significant concern.
■ Potable Water-Potable water contamination (primarily PCE and TCE) appears to be limited to the
four residences adjacent to the site and in the on-site deep (510 foot) well. PCE results were: Parnell
(70 µg/L), Glosson ( I 00 µg/L), Beaver ( 14 µg/L), Ivey ( I µg/L), and "new" deep (510 feet) on-site
well (4,000 µg/L). Sample results are summarized in Table 5-5. The on-site well had provided
drinking water for Ram Leather Care employees; however, it is no longer in use. None of the other
potable wells showed evidence of contamination.
Ram Leather Care S1.1perl1.1nd Site 5-6
• Interim Record of Decision Summary of Site Characteristics
■ Groundwatcr-VOCs were not detected in the three on-site shallow monitoring wells (well depths 20
to 32 feel). PCE contamination was detected in the surface and subsurface soil in the former drum
storage area to a depth of 45 feet. The groundwater in the former drum storage area is probably
highly contaminated. Additional groundwater data characterization and monitored natural
attenuation may be appropriate for this site. Performance monitoring is a critical component of this
remediation approach because monitoring is needed to ensure the remedy is protective and that
natural processes arc reducing contamination levels as expected.
The deep aquifer has not been sufficiently investigated to determine the extent of PCE
contamination. Limited information on the depth of several contaminated potable wells indicates.
that contamination of the deep aquifer is a problem. The known depths of three of the contaminated
potable wells are 250 feet (Parnell), 270 feet (Glosson), ·and 510 feet ( on-site deep well).
■ Surface Soil-Data generated during this investigation indicate that chlorinated solvent
contamination of surface soils is generally concentrated in the former drum storage area. Low levels
of PCE were detected in five samples collected in the former drum storage area. Pesticides were
detected in surface soils in the drum storage area and northern portion of the site. The highest
pesticide concentration detected was in the former drum storage area.
■ Subsurface Soil-The primary location of contaminated subsurface soil is the former drum storage
area. The chlorinated solvent contamination appears to be concentrated around the drilled hole in the
drum storage area. TCE, vinyl chloride, and other known PCE degradation products were detected in
this area. The highest concentration of PCE (78,000 µg/kg) detected was at the IO foot depth from
the drilled hole in the drum storage area. Adjacent to the drilled hole, 20,000 µg/kg of PCE was
detected at the 25 foot depth.
In the drum storage area, chlorinated solvents were detected in the soil down to the deepest sampling
depth of 45 feet. In several locations, the PCE level was higher at the 45 foot depth than the 20 to
30 foot depth. Drilling activities in August 1999 indicated that the depth to bedrock in_ the former
drum storage area is approximately 45 feet.
5.5 SUMMARY OF GROUNDWATER REMEDIAL INVESTIGATION (PHASE II)
5.5.1 Nature and Extent of Contamination
EPA completed the first 'phase of the RI in 1999 to assess the areal and vertical extent of contaminated
soil and groundwater at the site, and to determine whether additional potable wells adjacent to the site
were contaminated. In 2000, EPA tasked COM to undertake additional groundwater studies (Phase II).
The main objectives of the additional studies were to determine the nature of the fracture zones in the
area and the extent of contamination in the fractured bedrock aquifer. A review of the data collected
suggests that the extent of contamination has been defined to the north and west-northwest of the site,
but remains to be defined on the southern side and the east-northeast directions from the facility.
Additional characterization data is required for a long-term remedy.· Additionally, four private wells
sampled during the RI still showed unacceptable levels of contamination in the 2000 sampling event.
The data collected during the 1999 EPA RI and the 2000 COM groundwater investigation, as well as
earlier investigations, suggest that soils and groundwater at the siie and groundwater at neighboring
private wells are contaminated with chlorinated solvents typically associated with dry cleaning
operations. Limited full scan data that have been collected previously indicate that metals, SVOCs, and
pesticides are not a problem at the site. Figure 5-10 summarizes the known extent of contamination as a
Ram Leather Care Superlund S,te 5-7
• • Interim Record of Decision Summary of Site Characteristics
result of the investigations completed at the site. Site-related contaminants PCE, DCE, and DCA were
detected in groundwater samples from B-2/MW-5. Monitor well MW-7, located 1,000 feel
east-northeast of the Ram Leather facility, produced a groundwater sample with trace levels of DCE and
DCA. Site-related constituents were absent in samples collected from monitor wells MW-4 and MW-6.
Therefore, the extent of contamination has been estimated to the north and west-northwest of the site.
· The extent remains to be defined on the southern side and east-northeast directions from the facility.
Note that the two former potable on-site wells (the "old" and the "new") have high levels of
contamination. The four private wells in the immediate vicinity still show unacceptable levels of
contamination. Further, contamination appears to be increasing at the Glosson and Ivey wells.
Contamination migration pathways were evaluated in rock cores obtained from boring B-1. Analysis of
the cores showed a diagonal fracture pattern, suggesting pathways have existed for DNAPL and/ or
dissolved PCE in dry cleaning fluids to migrate downward to the subsurface. The depth of migration is
dependent primarily on the actual geometry of the fracture system, which cannot be determined without
detailed analysis.
5.5.2 Area of Contamination Proposed for Interim Action
On-site contaminated soil is an ongoing source for groundwater contamination. The FFS addressed the
on-site source in order to minimize additional release of source contaminants to groundwater. Remedial
alternatives for the area of contaminated soil identified during the RI were presented in the FFS.
Figure 5-11 indicates the area of soil contamination that will be addressed as part of the interim remedial
action. Although surface soil contaminant levels did not pose a human health risk, as indicated above,
contaminant levels in surface and subsurface soils may still impact groundwater. The potential for soil
contamination to impact groundwater in conjunction with the maximum contaminant level (MCL)
exceedances present in groundwater suggest the need to develop a soil remediation goal based on
groundwater protection. The RI indicated that some site soils exceed the conservative generic soil
screening level (SSL) for PCE for protection of groundwater (3 µg/kg) (EPN540/R-96/018). SSLs are
risk-based concentrations derived from equations combining exposure information assumptions with the
EPA toxicity data. It should be noted that SSLs are not considered national cleanup standards, but rather,
are useful in identifying and defining areas, contaminants, and conditions at a particular site that does not
require further federal attention. When a generic screening level is exceeded, it is useful to develop a
site-specific SSL. Figure 5-11 illustrates the approximate lateral extent of soils that exceed the SSL of
3 µg/kg PCE based on the RI data. These soils also exceed the North Carolina default number for soil to
groundwater leaching for PCE (7.4 µg/kg). While exceedances occurred at depths up to 40 feet below
ground surface (bgs), the depth of soil that would actually be addressed in this interim action extends
only to 26 feet bgs, the approximate depth to the groundwater table. Using the SSL allows the interim
action lo target the potentially most problematic soils regarding contamination of groundwater without
impeding the ability to collect additional site data needed to develop a final groundwater remedial action.
Based on an SSL of 3 µg/kg of PCE in soil for protection of groundwater, approximately 3,500 cubic
yards of surface and subsurface soils in the drum storage area would need to be addressed as part of the
interim action. Addressing these soils would also address other VOC contaminants that may exceed
North Carolina concentrations for soil to groundwater leaching.
5.5.3 Contaminant Fate and Transport
An evaluation of the potential environmental fate and transport of site-related contaminants is important
in determining the potential for exposure to contaminants. Because the data collected during this RI
indicate that the primary chemicals of concern are chlorinated solvents in groundwater at the site, this
section focuses on the potential fate and transport of chlorinated solvents in groundwater at the site.
Ram Leather Care S1.1perf11nd Site 5-8
• • Interim Record of Decision Summary of Site Characteristics
5.5.4 Contaminant Migration
Many factors influence the rate of contaminant movement in an aquifer system. These include the
physical/ chemical properties of the contaminants (e.g., solubility, density, viscosity, etc.) and the
physical/ chemical properties of the environment (e.g., soil penneability, porosity, bulk density, pH,
particle size distribution, etc.). Because all these factors can affect the rate of contaminant movement
through aquifers, it is very difficult to predict such movement; however, based on the data collected in
this RI and other investigations involving the transport of chlorinated solvents in aquifers, some gross
approximations of this movement can be made.
In general, once a contaminant reaches groundwater, it will move as groundwater moves, through the
process of advection. Advection is defined as the process by which solutes are transported by the bulk
motion of flowing groundwater. As discussed previously, water-bearing units that underlie the site
represent an aquifer system consisting of metamorphosed and fractured phyllite rocks of varying
proportions and thicknesses. In the site area, water is typically found in the saprolite aquifer and will
generally mimic the overlying land surface, with depth to water at about 12 feet bis and ground surface
sloping to the northwest and southeast, creating a groundwater divide. Thus, any movement of PCE
contamination at the site would be expected, for the most part, to be laterally in these directions.
However; given the complexity of bedrock at the site, the direction of groundwater flow depends
primarily on fractures, faults, bedding plants, etc. In addition, while advection is the primary transport
mechanism for contaminants in groundwater, the process of dispersion will also cause the contaminants
to spread both horizontally and vertically. Dispersion generally causes contaminants to migrate (spread)
farther than migration created by advection alone.
Ram Leather Care Superlund Site 5-9
• •
SECTION6
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USE
The property, which has been used for industrial purposes since I 973, is presently zoned residential; and
it is not anticipated that the land use will change in the future.
6.1 LAND USES
The site is a IO-acre parcel surrounded by residential property. To the south of the site is a 14-acre
parcel owned by Mr. Cliff Worley that includes a small pond used for fishing. To the east is the 8-acre
Glosson property ( 15208 Albemarle Road), and to the north, at 151 15 Albemarle Road, is a property
formerly owned by the Parnell family. The 18-acre Scoggins property at 14998 Coble Road is situated
west of the site. A small gravel road east of the site provides access to the Ivey and Beaver residences at
15148 and 15155 Albemarle Road, respectively. The Ram Leather Care Site is currently used for a flea
market.
6.2 AREA WATER USE
Most of the area within four miles of the site relies on private or community groundwater wells for
drinking water. A small area between 2 and 4 miles east of the site is served by public water from a
source outside the site vicinity. EPA has a removal action underway to extend public water supply lines
to the four residences that are known to have contamination in their wells. Approximately 7,900 people
obtain their drinking water from wells within four miles of the site.
Ram Leather Care Supertund Site 6-1
• •
SECTION7
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks
associated with current and future Site conditions. A baseline risk assessment is an analysis of the
potential adverse human health and ecological effects caused by hazardous substan·ce releases from a site
in the absence of any actions to control or mitigate these under current and anticipated future land uses.
The risk assessm~nt document for this Site, entitled Final Baseline Risk Assessment for Human Health
(June 2004), is available in the Administrative Record file.
7.1 HUMAN HEALTH RISK ASSESSMENT
A Superfund baseline human health risk assessment is an analysis of ihe potential adverse health effects
caused by hazardous substance exposure from a site in the absence of any action to control or mitigate
these under current and future land uses. A four-step process is utilized for assessing·site-related human
health risks for reasonable maximum exposure scenarios.
7.2 HAZARD IDENTIFICATION
In this step, the contaminants of concern (COCs) at the Site in various media (i.e., soil and groundwater)
are identified based on such factors as toxicity, frequency of occurrence and fate ~nd transport of the
contaminants in the environment, concentrations of the contamina~ts in the specific media, mobility,·
persistence, and bioaccumulation.
7.3 EXPOSURE ASSESSMENT
In this step, the different exposure pathways through which.people might be exposed to the contaminants
identified in the previous step are evaluated. Examples of exposure pathways include incidental
ingestion of and dermal contact with contaminated soil. Factors relating to the exposure assessment
include, but are not limited to, the concentrations that people might be exposed to and the potential
frequency and duration of exposure. Using these·factors, a "reasonable maximum exposure" scenario,
which portrays the highest level of human exposure that could reasonably be expected to occur, is
calculated.
7.4 TOXICITY ASSESSMENT
In this step, the types of adverse health effects associated with contaminant exposures and the
relationship between magnitude of exposure and severity of adverse effects are determined. Potential
health effects are contaminant-specific and may include the risk of developing cancer over a lifetime or
other non-cancer health effects, such as changes in the normal functions of organs within the body (e.g.,
changes in the effectiveness of the immune system). Some contaminants are capable of causing both
cancer and non-cancer health effects.
Ram Leather Care Superfund Site 7-1
• • Interim Record of Decision· Summary of Site Risks
7.5 RISK CHARACTERIZATION
This step summarizes and combines outputs of the exposure and toxicity assessments to provide a
quantitative·assessment of site risks. Exposures are evaluated based on the potential risk of developing
cancer and the potential for non-cancer health hazards. The likelihood of an individual developing
cancer is expressed as a probability. For example, a 104 cancer risk means a "one-in-ten-thousand excess
cancer risk"; or one additional cancer may be seen in a population of I 0,000 people as a result of
exposure lo site contamin,mts under the conditions explained in the Exposure Assessment. Currenl
Superfund guidelines for acceptable exposures are an individual lifetime excess cancer risk in the range
of 10.., to 10·' (corresponding to a one-in-ten-thousand to a one-in-a-million excess cancer risk) with 10·6
being the point of departure. For non-cancer health effects, a hazard index (HI) is calculated. An HI
represents the sum of the individual exposure levels compared to their corresponding reference doses.
The key concept for a non-cancer HI is that a "threshold level" (measured as an HI of less than one)
exists below which non-cancer health effects are not expected to occur.
The human health estimates summarized here are based on current reasonable maximum exposure
scenarios and were developed by taking into account various conservative.estimates about the frequency
and duration of an individual's exposure to the COCs in the various media that would be.representative
of site risks, as we 11 as the toxicity of these contaminants. As was noted above, the current land use of
the property is residential, and it is'not anticipated that the land use will change in the future. Since the
area is not served by municipal waler, it is likely that the groundwater underlying the property will be
,used for potable purposes in the foreseeable future; however, since regional groundwater is designated as
a drinking waler source, hypothetical exposure to groundwater was evaluated. The other media that were
evaluated included surface and subsurface soil. The primary COCs in groundwater are cis-1,2-DCE,
PCE, TCE, 1,2-DCE, and chloroform. In surface soil, the primary COCs are toxaphene and manganese.
Tables 7-1 through 7-5 summarize COCs for all media evaluated and the medium-specific exposure point
concentrations.
The baseline risk assessment evaluated the health effects which could result from exposure to
contaminated property-related media through ingestion, dermal contact, or inhalation. The assessment
evaluated hazards and risks to on-property trespassers and future on-property workers exposed to surface
soils, future on-property construction and utility workers exposed to subsurface soils, and hypothetical
on-properly workers and hypothetical off-property adult and child residents exposed to potable
groundwater. Table 7-6 summarizes exposure pathways for the Site.
The results of the baseline risk assessment indicate that the contaminated surface soil on the properly
poses no risk. The contaminated groundwater at the Site poses an unacceptable risk to human health, due
primarily lo the presence of VOCs. Tables 7-7 and 7-8 present a summary of the cancer toxicity data
used to calculate carcinogenic risks. Tables 7-9 and 7-10 present a summary of the non-cancer toxicity
data used lo calculate noncarcinogenic risks.
7.5.1 Summary of Risks Associated with the Surface Soil
Risks and hazards were evaluated-for incidental ingestion of, dermal contact with, and.inhalation of
particulates released from surface soil. The total incremental lifetime cancer risk estimates are:
• Current adult worker: 2 x 10·1 (two in ten million)
• Current adolescent visitor: 3 x I 0·3 (three in one hundred million)
■ Future child/adult resident: 7 x 10·7 (seven in ten million)
These estimates are below EPA's target range of 10·0 lo 10·4_
Ram Leather Care Superfund S,te 7-2
• • Interim Record of Decision Summary of Site Risks
His greater than one indicate the potential for non-cancer hazards. The calculated His are:
■ Current adult worker: 0.01
■ Current adolescent visitor: 0.005
·• Future child resident: 0.1
Non-cancer hazards are not expected for current adult workers, current site visitors, or future child
residents based on His less than one.
7.5.2 Summary of Risks Associated with Groundwater
Risks and hazards were evaluated for ingestion of groundwater. The total incremental lifetime cancer
risk estimates are:
■ Current child/adult resident (Private Well 0011): 6 x 10·5 (six in ten thousand)
■ Current child/adult resident (Private Well 0113): 9 x 10·5 (nine in ten thousand)
■ Current child/adult resident (Private Well 089): 9 x 10·7 (nine in ten million)
■ Future child/adult resident: 3 x 10·3 (three in one thousand)
Risks associated with current private well use are within EPA's target risk range of 10·' to IO"'. Risk
associated with consumption of water from future use of water obtained from the on-site well are well
above EPA's target risk range of 10·' to 10"'.
An HI greater than one indicates the potential for non-cancer hazards. The calculated HI is:
■ Current child resident (Private Well 001 I): 0.5
■ Current child resident (Private Well O 113): 3
■ Current child resident (Private Well 089): 0.004
■ Future child resident: 33
Based on this HI, there is a potential for non-cancer health effects to occur from residential use of
groundwater. The constituents that contribute most significantly to residential HI estimates are PCE and
cis( 1,2-DCE). The HI for Private Well 0113 is greater than one, indicating non-cancer effects are
possible. However, when critical effect is examined, none exceeds one; this indicates that non-cancer
effects are not likely.
7.6 UNCERTAINTY ANALYSIS
The uncertainty analysis provides decision-makers with a summary of those factors that significantly
influence risk results and discusses the underlying assumptions that most significantly influence risk.
This section discusses the assumptions that may contribute to over-or underestimates of risk.
7.7 UNCERTAINTIES RELATED TO EXPOSURE ASSESSMENT
The exposure scenarios contribute a considerable degree of uncertainty to the risk assessment. Actual
exposure frequencies are unknown; estimates were based on available guidance. Actual exposure is not
expected to exceed the values presented, but may be lower. The use of conservative assumptions in the
exposure assessment is believed to result in a potential overestimate of risk. Actual site risk may he
lower than the estimates presented here, but is not likely to be greater.
Ram Leather Care Superfund Sire 7-3
• • Interim Record of Decision Summary of Site Risks
Not all potential receptors were examined. For example, subsurface soil contamination exists in the area
immediately west of the facility. Excavations in this area by a construction worker could result_ in
exposure to_ contaminated soil. Although this scenario was not examined, contamination in the
subsurface was not ignored. The FFS report (June 2004) evaluates the contamination in this area as a
protection of groundwater issue. The resultant proposed cleanup levels are considerably lower (more
protective) than would be generated had a construction worker scenario been considered.
7.8 UNCERTAINTIES RELATED TO TOXICITY INFORMATION
Reference dose values (RfDs) and cancer slope factors (CSFs) for the chemicals of potential concern
(COPCs) were derived from EPA sources. RfDs are determined with varying degrees of uncertainty,
depending on such factors as the basis for the risk (no-observed-adverse-effect-level, NOAEL versus
lowest-observed-adverse-effect-level, LOAEL), species (animal or human), and professional judgment.
The calculated risk is, therefore, likely overly protective; and its use may result in an overestimation of
non-cancer risk. Similarly, the CSFs developed by EPA are generally conservative and represent the
upper-bound limit of the carcinogenic potency of each chemical.
7.9 UNCERTAINTIES RELATED TO GROUNDWATER DATA
The groundwater data that were used in this assessment contribute a significant degree of uncertainty to
the overall assessment. Among the factors that should be considered are the use of a single sampling
event to estimate risk in the future. The presumption that contaminant concentrations will remain the
same over time may overestimate the potential risk, because dispersion and other natural processes are
not accounted for.
7.10 UNCERTAINTIES RELATED TO INCOMPLETE SITE CHARACTERIZATION
The site is in a fractured bedrock environment, which means that groundwater flow patterns a'rc difficult
to predict. Consequently, defining the extent of groundwater contamination in the conventional sense is
a major challenge. Investigations that have been conducted since the early 1990s have shown that the
wells on-site are highly contaminated, while four private wells near the site are also impacted, but to a
lesser degree. To date, no other private wells have been shown to be significantly impacted. However,
since the area is not served-by a public water system, regular monitoring of potentially impacted private
wells is a prudent course for the foreseeable future.
7.1 I ECOLOGICAL RISK ASSESSMENT
EPA evaluated the potential for ecological risks at the Ram Leather Care site. Ecological risk assessment
addressed the objectives set forth by the NCP, 40 Code of Federal Regulations (CFR) 300, under the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 for protection of the
environment from current and potential threats posed by an uncontrolled hazardous substance release.
After evaluation of the Screening-Level Ecological Risk Assessment, EPA determined that there was no
. ecological risk associated with the site.
Ram Leather Care Superfund Sita 7-4
• •
SECTIONS
REMEDIAL ACTION OBJECTIVES
CERCLA and the National Contingency Plan (NCP) define remedial action objectives (RAOs) that are
applicable to all Superfund sites. They relate to the statutory requirements for the development of
remedial actions. Site-specific remedial goal options (described in Table 8-1) relate to potential exposure
routes and specific contaminated media, such as soil, and are used to identify target areas of remediation
and contaminant concentrations. They require an understanding of the contaminants in their respective
media and are based upon the evaluation of risk to human health and the environment, protection of
groundwater, information gathered during the RI, applicable guidance documents, and federal and state
applicable or relevant and appropriate requirements (ARARs). RAOs are as specific as possible without
unduly limiting the range of alternatives that can be developed for detailed evaluation.
In consideration of the COCs and remedial goal options (RGOs), RA Os for groundwater at the site may
include the following:
• prevent ingestion of groundwater having concentrations in excess of remediation goals;
• restore the groundwater aquifer system by cleanup to the remediation goals, and prevent the
migration of the pollutants beyond the existing limits of the known contaminant plume or established
point of compliance; and to
• control future releases of COCs in groundwater to ensure protection of human health and the
environment. While the completion of the interim action developed as a result of the FFS will work
to achieve the RA Os, the primary immediate objectives of the interim action are to reduce site risks
by preventing exposure to contaminated groundwater and further migration of contaminants, and to
provide additional site data. Specifically, the interim action would:
prevent exposure to contaminated groundwater,
reduce migration of the contaminant plume,
reduce migration of contaminants from sources, llfld
provide additional site data to assess restoration potential.
Ram Leather Care Superfund Site 8-1
• •
SECTION9
DESCRIPTION OF ALTERNATIVES
Many technologies were considered to clean up the Site. Appropriate technologies were identified and
screened for applicability to site conditions in an FFS (groundwater and soil). The potential technologies
were then assembled into alternatives in the FFS. Potential remedial alternatives of the Site were
identified, screened, and evaluated in the FFS. The range of alternatives developed included no action,
institutional controls, containment, treatment, and disposal. The alternative numbers used in the FFS
identify the alternatives.
9.1 DESCRIPTION OF GROUNDWATER ALTERNATIVES
9.1.1 Alternative GI: No Action
Estimated Capita I Cost: $0
Estimated Annual O&M Cost: $0
Estimated 5-Year Review Cost: $8,000
Estimated Present Worth Cost: $32,000
Estimated Construction Time, Frame: None
Regulations governing the Superfund program generally require that the "no action" alternative be
evaluated to establish a baseline for comparison. Under this alternative, EPA would take no action at the
site to prevent exposure to the groundwater contamination. Since hazardous wastes would remain
on-site, 5-Y car Reviews would be required.
9.1.2 Alternative G2: Pump and Treat with Biological Treatment and Groundwater Monitoring
Estimated Capital Cost: $527,000
Estimated Annual O & M Cost: $485,000
Estimated 5-Year Review Cost: $8,000
Estimated Present Worth Cost: $1,0/0,000
Estimared Time Frame: 5 years
For this alternative, groundwater would be pumped from existing in-place wells for treatment via an
ex situ biological reactor. Biological reactors use m\croorganisms to degrade organic contaminants in
groundwa~er through either an in·situ or ex situ treatment system. Aerobic reactors use oxygen to
promote biodcgradation. Organic compounds are decomposed to carbon dioxide and water (aerobic) or
to methane and carbon dioxide (anaerobic). VOCs are remo~ed by volatilization as a competing
mechanism. The alternative also involves the continued monitoring of groundwater in nearby private
wells.
9.1.3 Alternative G3: Pump and Treat with Physical/Chemical Treatment and Groundwater
Monitoring
Estimated Capital Cost: $441,000
Estimated Annual O& M Cost: $485,000
Estimated 5-Year Review Cost: $8,000
Ram Leather Care Supe,tund Site 9-1
• Interim Record of Decision
Estimated Present Worth Cost: $926,000
Estimated Construction Time Frame: 5 years
• Description of Alternatives
Alternative G3 consists of pumping groundwater from existing in-place wells to an on-site wastewater
. treatment system, and subsequent discharge to surface water. Pumping may be continuous or pulsed to
allow equilibrium of contaminants with the groundwater. In order to design the various components of
the groundwater recovery and treatment system, a short-term aquifer test and/or specific capacity test will
be run. At various times during testing, samples of recovered water will be collected and analyzed in
order to determine the probable quantity of water that will be pumped from the recovery well over the
long term. PCE and related contaminants could be removed from groundwater via air stripping, the use
of granular activated carbon (GAC), or chemical/ ultraviolet (UV) radiation. The alternative also
involves the continued monitoring of groundwater in the aquifer and nearby private wells. Deed
restrictions may be placed on the Site while remedial action takes place.
9.2 DESCRIPTION OF SOIL ALTERNATIVES
9.2.1 Alternative Sl: No Action
Estimated Capital Cost: $0
Estimated 5-Year Review: $8,000
EsTimated Annual O&M Cost: $0
Estimated Present Worth Cost: $21,000
Estimated Construction Time Frame: <1 year
Regulations governing the Superfund program generally require that the "no action" alternative be
evaluated to establish a baseline for comparison. Under this alternative, EPA would take no action at the
Site to prevent exposure to the soil contamination. Since hazardous wastes would remain on-site, 5-Year
Reviews would be required.
9.2.2 Alternative S2: On-Site Treatment with Soil Vapor Extraction
Estimated Capital Cost: $259,000
Estimated 5-Year Review: $8,000
Estimated O&M Cost: $892,000
Estimated Present Worth Cost: $1,150,000
Estimated Construction Time Frame: 5 years
This alternative involves the in situ treatment of soil using soil vapor extraction. Alternatively,
contaminated materials could be excavated, transported to a central area on-site for consolidation and
staging, and treated via ex situ soil vapor extraction. Treated material would be backfilled on-site. The
final treatment system would depend upon the outcome of treatability testing and would be determined
during the remedial design phase.
9.2.3 Alternative S3: Excavation, Off-Site Transportation and Disposal at Subtitle C or D Landfill
Estimated Capital Cost Subtitle C: $1,960,000
Estimated Capital Cost Subtitle D: $963,000
Estimated O & M Cost: $188,000
Estimated Present Worth Cost Suhtitle C: $2, I 50,000
Estimated Present Worth Cost Subtitle D: $1,150,000
Ram Leather Care Superfund Site 9-2
• • Interim Record of Decision Description of Alternatives
Estimated Time Frame: I year
This alternative consists of transporting contaminated soils off-site to a Subtitle D landfill, on the
assumption that the soil is considered not hazardous by definition. This alternative will remove from the
Site all contaminated soil. If the soils are determined to be hazardous, soils will need to be disposed of in
a RCRA-secured Subtitle C landfill.
Ram Leather Care $(Jperlund Site 9-3
• •
SECTION 10
COMPARATIVE ANALYSIS OF ALTERNATIVES
This section presents a cornparative analysis of the groundwater alternatives, based on the threshold and
balancing evaluation criteria. The objective of this section is to compare and contrast the alternatives so
that decision-makers may select a preferred alternative for presentation in the Interim ROD.
The alternatives are presented here to give decision-makers a range of potential actions that could be
taken to remediate this site. For groundwater, these actions include:
■ no action,
• pump and treatment via biological treatment with groundwater monitoring, and
• pump and treat via physical/chemical treatment with groundwater monitoring.
For soil, these actions include:
■ no action,
■ in situ soil vapor extraction, and
■ off-site disposal.
Tables 10-1 and 10-2 present a summary of each remedial alternative along with ranking scores for each
evaluation criterion. Each alternative's performance against the criteria (except for present worth) was
ranked on a scale of0 to 5, with 0 indicating that none of the criterion's re_quiremenls were met and 5
indicating all of the requirements were met. The ranking scores are not intended lo be quantitative or
additive, but rather are summary indicators of each alternative's performance against the CERCLA
evaluation criteria. The ranking scores, combined with the present worth costs, provide the basis for
comparison among alternatives.
For groundwater, Alternatives 2 and 3 rank higher than Alternative I in overall protection of human
health and the environment, compliance with ARARs, long-term effectiveness and permanence, and
reduction of mobility/toxicity/volume (M/T/V). Alternative 3 ranks higher than Alternative 2 in
short-term effectiveness and implementability.
For soil, Alternatives 2 and 3 are ranked higher than Alternative I across all the criteria, except
short-term effectiveness and implementability. Alternatives 2 and 3 are the same for overall protection,
compliance with ARARs, and long-term effectiveness and permanence. Alternative 3 is ranked lower
than Alternative 2 in reduction of M/T/V through treatment, since it only reduces mobility. However,
Alternative 3 is ranked higher than Alternative 2 in implementability, since Alternative 2 may require
trealability testing to determine its effectiveness.
As previously noted, estimated costs for each of the soil remedial alternatives arc based on estimated
volumes of contaminated soils only. Total volumes requiring remediation and, therefore, total estimated
costs for the alternatives will likely require development of site-specific soil remediation goals for the
protection of groundwater. The final determination of the volume of soil to be remediated, as well as the
collection of additional site information, will influence the feasibility of the various alternatives.
Ram Leather Care Superfund Site 10-1
• •
SECTION 11
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address principal threats posed by a
site wherever practical. A principal threat concept is applied to the characterization of "source material"
at a Superfund site. A source material is material that includes or contains hazardous substances,
pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface
water, or air, or acts as a source for direct exposure. EPA has defined principal threat wastes as those
source materials considered to be highly toxic or highly mobile, and generally cannot be reliably
contained or would present a significant risk to human health or the environment should exposure occur.
The decision to treat these wastes is made on a site-specific basis, through a detailed analysis of
alternatives, using the remedy selection criteria described in Section 9. This analysis provides a basis for
making a statutory finding that the interim remedy employs treatment as a principal element. The
magnitude of the PCE concentrations in the aquifer indicates the potential presence of this contaminant
in the form of a DNAPL, a principal threat waste.
Ram Leather Care Superfund Site 11-1
•
SECTION 12
THE SELECTED INTERIM REMEDY
The selected interim remedy meets the requirements of the two mandatory threshold criteria: protection
of human health and the environment and compliance with ARARs while providing the best balance of
benefits and tradeoffs among the five balancing criteria: long-term effectiveness and permanence, short-
term effectiveness, implementability, reduction of M/T/Y through treatment, and cost. The selected
remedy also includes flexibility, to the maximum extent practical, to allow for future redevelopment of
the Site. Input from the State of North Carolina, local municipalities, and the community were critical
components that were considered. The selected remedy meets the RAOs presented in Section 8 and are
described below:
• Excavation, off-site transportation, and disposal at Subtitle D landfill; and
• Pump and treat with physical/chemical treatment and groundwater monitoring.
12.1 ALTERNATIVE S3: EXCAVATION, OFF-SITE TRANSPORTATION, AND DISPOSAL
AT SUBTITLED LANDFILL
This alternative consists of transporting contaminated soils off-site 10· a RCRA Subtitle D landfill, on the
assumption that the soil is not considered hazardous by definition (i.e., listed RCRA hazardous waste). If
it is considered a hazardous waste, the soil will have to go to a Subtitle C landfill. This alternative will
remove from the Site all contaminated soil. Water would be used to minimize fugitive dust emissions
during soil excavation, transport, and handling. Cost estimates are detailed in Tables 12-1 and 12-2.
12.2 ALTERNATIVE G3: PUMP AND TREAT WITH PHYSICAUCHEMICALTREATMENT
AND GROUNDWATER MONITORING
Alternative 3 consists of pumping groundwater from an existing on-site well to an on-site wastewater
treatment system, and subsequent discharge to surface water. Pumping may be continuous or pulsed to -
allow equilibration of contaminants with the groundwater. In order to design the various components of
the groundwater recovery and treatment system, a short-term aquifer test and/or specific capacity test will
be run. At various times during testing, samples of recovered water will be collected and analyzed in
order to determine the probable quantity of water that will be pumped from the recovery well over the
long term.
PCE and related contaminants could be removed from groundwater via air stripping, the use of GAC, or
chemical/UY radiation. Air stripping uses volatilization to transfer contaminants from groundwater to
air. The second process applicable to groundwater contamination at the site, the use of GAC, removes
contaminants from groundwater by absorption. Chemical oxidation uses chemical oxidizing agents to
destroy toxic organic chemicals in groundwater. Continued groundwater monitoring is required to ensure
the remedy is protective and that natural processes arc reducing contamination levels as expected.
Institutional measures may be required to prevent prolonged exposure to contaminants. The cost
estimate is contained in Table 12-3.
12.3 SUMMARY OF ESTIMATED INTERIM REMEDY COST FOR SOILS AND
GROUNDWATER.
Ram Leather Care Superfund Site 12-1
• • l11terim Record of Decision The Selected Interim Remedy
The total present worth for soil Alternative 3 is $1.15 million. The estimated capital costs are $963,000
and the estimated operation and maintenance (O&M) costs are $188,000.
The total present worth for groundwater Alternative 3 is $926,000. The estimated capital costs are
$306,000 and the estimated O&M costs are $485,000.
Ram Leather Care Superfund Sile 12-2
• •
SECTION 13
STATUTORY DETERMINATIONS
Under CERCLA § 121 and the NCP, the lead agency must select remedies that are protective of human
health and the environment, comply with ARARs (unless a statutory'waiver is justified), arc cost-
effective, and utilize permanent solutions to the extent practicable. In addition, CERCLA includes a
preference for remedies that employ treatment that permanently and significantly reduces the M/T/V of
hazardous wastes as a principal element. The following sections discuss how the selected remedy meets
these statutory requirements.
13.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy will protect human health and the environment by:
• Preventing unacceptable exposure risk to current and future human populations presented by direct
contact, inhalation, or ingestion of contaminated groundwater.
• Monitoring any possible future migration of COCs into previously uncontaminated portions of the
deep aquifer to provide advanced notice of changes in plume direction and concentration.
• Preventing unacceptable exposure risks to current and future ecological receptors presented by
contact, ingestion, inhalation from contaminated materials, or COCs derived from the source area.
• Providing that_the future migration of contaminants from the source is within limits and considered
protective of groundwater.
• Facilitating redevelopment of the site consistent with current and future plans and zoning ordinances
(reasonably anticipated future land use).
13.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected remedy will comply with federal and state ARARs that have been identified. No waiver of
any ARAR is being sought for the selected remedy. Only the state ARAR is identified when a situation
occurs in which the state ARAR is more stringent than the corresponding federal ARAR, or where
requirements from the state program have been federally authorized. The ARARs for the remedy are
identified in Tables 13-1 to 13-8.
Ram Leather Care Superfund Site 13-1
•
SECTION 14
REFERENCES
•
COM (COM Federal Programs Corporation) 2004. Final Focused Feasibility S1t1dy Report, Ram
Leather Site, Mecklenburg County, North Carolina, June.
COM 2004. Final Baseline Risk Assess111entfor Human Health, Ram Leather Site, Mecklenburg County,
North Carolina, June.
LeGrand, H. E., and M. J. Mundorff 1952. Geology and Groundwater in the Charlotte Area, Bulletin 63,
North Carolina Geological Survey.
Means, R.S. 1999. ECHOS (Environmental Cost Handling Options and Solutions) Environmental
Remediation Cost Data-Unit Price, 1999.
NCDEHNR (North Carolina Department of Environment, Health and Natural Resources) 1996.
Combined Preliminary Assessment/Site Inspection, Ra111 Leather Care, Vol. I and II, March.
Stanley, Jeanette 1998. Hand written notes given to Michael Profit, COM, Re: Well Depths on and near
Ram Leather Site (North Carolina Department of Environment, Health and Natural Resources),
November 12.
U.S. Environmental Protection Agency (U.S. EPA) 1989. Risk Assessmelll Guidance for Supe,fund:
Human Health Evaluation Manual (Part A), Appendix A, December.
U.S. EPA 2000. Remedial Investigation/Feasibility Study, Ra111 Leather Site, Mecklenburg County,
North Carolina, March 14.
U.S. Geologic Survey (USGS) 1980. Topographic Map, 7.5-Minute Quadrangle, Midland, North
Carolina.
Ram Leather Care Superfund Site I 3-1
OOUNTY LOE
PARO:~ solH)Aff'f
l#tH+H· RAILROAD
100 .. 200 -;;.;
F
•
Macklenbur u MapttJdfrom· 't Co. Land Rec;ds D , October 20()2_ecklenburg Co. Lan: R aerial photograph J ecords Div to · une 2001 Cl>IVI ., "'"'''"'' '""""'·
•
. Figure 1-l
Site Vicinity M Ram L ap
Charlotte N eather Site ' orth Carolina
•
•
Figure 5-1
Conceptual Site Model
Ram Leather Site
Primary
Sources
Process Area
CDM.
'--<
Primary
Release
Leaks and Spills --
-
\
Secondary
Sources
Soil
Groundwater
~-
-
-,-+
Secondary
Release
Intrusive Actions
_ Fugitive Dust,
Vapors
Volatilization
i-
f--:-<
{
Media
Affected
Soil
Air
Air
Groundwater
f------,
---,
I---'
---,
Exposure
Routes
Ingestion
Dermal Contact
Inhalation
Inhalation
Ingestion
-
-
~
Human
Receptors
Visitor
Worker
Resident
ViSitor
Worker
Resident
Resident
•
~ MW-0011
DRUM
STORAGE
AREA
Soura,· DES Resource Groups, Inc., survey, August 15, 2002.
CDM
•
0 MW-0022
SEPTIC
®TANK
PRESUME~/
DUMPSTER
LOCATION
0 MW0033
SEPTIC DRAIN
FIELD
0 MW-20
I
I
I
/
SEPTIC
DRAIN FIELD
HEAD BOX
LEGEND
tSl MONITORING WELL
{!) PRIVATE/DRINKING WATER WELL
+++++++ RAILROAD
0 ~ 100 1~ ~----➔ I I Scale in Feet
Nortll Carolina State Plane, NAO 83
Figure 5-2
Site Features Map
Ram Leather Site
Charlotte. North Carolina
•
~ MW-0011
DRUM
STORAGE
AREA
Source· DES Resource Groups, Inc .. survey, August 15, 2002
CDM
•
0 MW-0022
PRESUME~/
DUMPSTER
LOCATION
0MW-0033
SEPTIC DRAIN
FIELD
0 MW-20
I
I
I
/
SEPTIC
DRAIN FIELD
HEAD BOX
LEGEND
S MONITORING WELL
• PRIVATE/DRINKING WATER IIIIELL
~ RAILROAD
0 50 100 150 P-....-_.... I I
Scale in Feet
North Carolina State Plane. NAO 83
Figure 5-2
Site Features Map
Ram Leather Site
Charlotte. North Carolina
• Figure Drum Storage Area. 5-3 • ~:-··· . ..f, ., --~•. •·-~-r d\~;'.:t:t:1T{' , ' .. =s . ' ' . . .... '"'•·., ._ . -. ' ... ,·. . -.. ; """'J•-,, . . . · .. ' . • .•. ' .. c·•J •·: · ;-,,_'fc' . --;, • .. ', • ; ' : • ' ·--0. '. .. ), C:.' .'. C : ,.,,.,,..~_ .,;,. •;._c_ ·,·-: · '-<{. ,;:;.,.,..,_k,·: -:-.v:·; • . -S.., • ., .. .. ·, .. ·~-, .>h• •·.. • ~ '-~"1-iz..;,:.·, .. , •.. . .;;~_,.,.<';,,'1.,,, '",;''~ .. JJ.t: ·;, 11111 _,,. ~~-----. -~, •, ' <L-, . • ... ,, ... ,~,. ~ •. V "· ~.. .., -,... .• • . ,, ., . ' • ' f<· .... 'C'S' "' . ' : .• --r;;,.,..p. . . :, <", . . -., , ~; ">.c.., '· 'c.·":.· •• _., ~,. iC-"¾ ... -.. ..... . •.' •• ..... : ,... • , ........ _ ··• ..,,,, •. _ .... · .. ·----~,. ' • . . w --. . .. ,.. .,-·. ', . .,., : "', .. . " ~ ·. '"'=·,'. • '-' .. .,.,,... .... , 'c, ... . . . ·•• "';,· .• ,,,-_: ·;.•,, •• , ..... ,.'$! .•. ·•-,,,,,,.,, ••• •·. ··-,·~, ·'··'h t ·,:" '·• .... ..,, > .... , --~-•-.,e.,. r(,.,, .,. .._,.. • • . . 1'·' ... •L'!t .•. : .... .,.. ., . l <-,-h •.•. , .. ..,_._...,. ·' . . .. ,-:~~.,~-..,~. :.z _ ..... ,;t,½~;7!'_ -.. [I,. ·:v:::':, .. _\ _; · ...... ,' -.,·; ...__,_, "'' -·'·'•-· "'···. ·1 · "-,"'-' ...... , • ,.-<". ·f ,)1 > ::-~--•• • • ·o..,>·.. . . ~-... ' ·. .... -. ' .. ·-:,.. • .. '·--x:;.,,. ·_ . ; .; •~ ·"'' .-•, ;,:;,-,.k. •. :, ..• ·, , .. ,~_. )\ "·'•· ... , , ... "'"'" ,.. ' • •. ,, • • . , • , ,. ··' •• f.. •• "' . . ........ ,.. .., ... , . .. . . -. . . . . ; ' . .... , ...• , ... , . .,, ~ .. . ·-:.;... . ' .. " .. . .. . .•. ·•·:•1'_: .. , .;,, ~•';,:,:·. '. ... ' . '. ,« .• ··'-'':,:,;-.•. \ "· . ··• .. , .. r,. . .. . . ' ,·, •~\.u.._. · .. • .. '• t~/r?.t:;:_\ ~ •::; '\< · .. r . f:.-:: ~.,, • ,_ £;;.."'· Jit . .•. ,_ ... · .•·. , .... ,. ~~~r;-~;-. -. :... .. , -. •· 1.1 . Figure Uncovered Hole in Drum Storage Area. 5-4 *
•
Sources; DES Resource Groups, Inc., survey, A'915115, 2002.
Mecklenburg Co Land Records Div .• aerial photograph, June 2001
Adapted .tom: Mecklenburg Co. Land Records Div .. topogaphic attributes,
October 2002
CDNI
•
PRIVATEA>RIN<ING ""'TER W3..l
MONIT~YIELI.
~ RAILR~
PARCEL BOlHlARY
COUNl'YUNE
100 200 w ;;;j
400
I
Figure 5-5
Private Wells in Site Vicinity
Ram Leather Site
Charlotte, North Carolina
\
•
B-17 •
OLD
WELL
B-10 e
B-16 e
DRUM
STORAGE
Legend
TRASH
PILE
AREA
• Soll Boring Sample Locations
(. Monitoring Well Locations
Private/Drinking Water Well Locations
Property Boundary
,.............. Railroad
O ~ 100 e----____. I
Scale in Feet
North Carolina State Plane, NAO 83
So..-ces (1) DES Resource Groups, Inc , survey, August 15, 2002
(2) NCOEHNR 1996
CDM
•
"r MW-0022
",E PI I•
fAIH'
'<~,c se ~ '-'~
\ FLOOR DRAIN
FROM BUILDING
TO UNDERNEATH
CONCRETE PAD
B-2• /
PRESUME~
DUMPSTER
LOCATION
,,--
I PILE OF1
/ DEBRIS/
\ AND /
\ SOIL / ----
8-6 • • 8-4
SEPTIC DRAIN
~
MW-2D
FIELD
SEPTIC 7 DRAIN FIELD
HEAD BOX
e B-5
Figure 5-6
Bold Research Labs Sample Locations
Ram Leather Site
Charlotte, North Carolina
legend
TRASH
PILE
•
OLD WELL
• SS-02
DRUM
STORAGE
AREA
e Surface Soil Sample Locations
6i Monitoring WeU locations
Private/Drinking Water \11/eU Locations
Property Boundary
.............. >+ Railroad
0 50 100
e-, ----I Scale 1n Feet
North Carohna State Plane, NAO 83
e SS-04
Soun:es (1) DES Resource Groups, Inc, survey, August 15, 2002
(2) NCDEHNR 1996
CDM
•
"w MW-0022
\ FLOOR DRAIN
FROM BUILDING
TO UNDERNEATH
CONCRETE PAD
✓-
/PILE OF")
1 DEBRIS/
\ AND ;
\ SOIL / ----
/
PRESUME~
DUMPSTER
LOCATION
SEPTIC DRAIN
FIELD
~
MWW
,..,.,..-
~
-SEPTIC
/ DRAIN FIELD
✓ HEAD BOX
Figure 5-7
EPA Technical Assistance Team Sample Locations
Ram Leather Site
Charlotte. North Carolina
!
l 111o&
. t-toft
, , . \ , 0 MW0022
Ram Leather
Charlotte, North Carolina
CDM Federal Programs Corporation
MW0011 A
ei.
Legenu
oca ion~ 1999 RI On-Site Sample L t·
Snl Samr,h
Mon11onng Nell
Pr,,a1e Drinking Natrr N,~11
c:,ut;~uriace Su,I Samplt
SeptJ, Drain Field
Pr1_ pc-rt, Sountlan
~r11ln.J01
I l~lth. ~ ••
0
\
\
•
\
\
200
Scale ,n Feat
\
Parnell •
PW0011 /
/
MW0022 0
•
/
/
\
\
\
\
/
, , d fl311!06
ov1'ffJff'
IQl'l-s
~0(\1\
~.,,_
PW0113
/
/
/
Ram Leather
Charlotte, North Carolina
COM Federal Programs Corporation
\
I
I
I
I
J---------
l__
I
_j
I
I
I
Legend
1111 I
I.
\
~
\
0 200
Scala on Feet
Soil Sample
Monitoring Well
Private/Drinking Water Well
Septic Drain Field
Property Boundary
Railroad
400
1999 RI On-Site and Off-Site Sample Locations
Figure No.
5-9
08/01
0
•
0011
e •0s1
\
~W0011 J"O . ') osoi•
1S1" \ • 0:,,1t
\
\
\
200
Scale in Feet
e MV.0033
\
\
0
Parnell • \ --
PW001 I _,.,-
MW0022 e
SS5 .-=-5-!
~
S5J •
•
-----
/
/
\
\
\
\
\
\
/
I \
I
) \ ____
./\Glosson
~~113
I
I
I
)-I
----_J ----/
/
/"'-.
/ "" ""
<> "" .:~<;>◊ "" "" •
I
I I
I I
----
Legend
I ! 111
\
---------
---------\
---------\)
"·-~p----
---------\
• \
--------------
0 200 400
Scale in Feet
Soil Sample
Monitoring Well
Private/Drinking Water Well
Septic Drain Field
Property Boundary
Railroad
Ram Leather
Charlotte, North Ca rolina
CDM Federal Programs Corporation
1999 RI On-Site and Off-Site Sample Locations
Figure No.
5-9
08/01
Legend
TRASH
PILE
•
RL25 • •□sa
RL21
A
D Approximate Extent or Contaminated
Soil to be Addressed
Surface Soil Sample Location
Subsurface Soil Sample Location
Monttoring Well Location
-:--Private/Drinking Water Well Location
Property Boundary
............,.. Railroad
0 50 100 1---1 .---1 I Scale 1n Feet
North carohna State Plane, NAO 83
Soun;e DES Resource Groups, Inc . survey,
August 15, 2002
Source DES Resource Groups, Inc., survey, August 15, 2002.
CDM
.NOi
SEPTIL.
TANK
•
~ MW--0022
•ss2
s
v,,,,,,
•ou2
sss •
SEPTIC DRAIN
FIELD
MW-2D
------
.SS3
.SS4
Figure 5-11
Approximate Extent of Soil to be Addressed
Ram Leather Site
Charlotte. North Carolina
• •
Table 2-1
Soil Samples Collected by Ram Leather Care, 1991
Mecklenburg County, North Carolina
U,,,U,J('U~W't.&IW.i~,!:!!f~i,;1,1~:.,.~,:/_,\~..ll,\'.:1\.P!~.1-, ,,,~,-,1>'tf• ,.1,.-l 'l. ,.',:,,11.,...:i, ••• 1,..;11, .' ,,-\, •~,• ' •·' ! ".:~'S ~ ~:f!#i~'fil~ Uffi!'Ti',4 ;. '··i :t,;f•;r.,1 'Depth of Sample~t 'PCE Results'1: --rcA• ~ · ... Mineral'' • , 1,,1 \:.,) , ii t • !oil-, .,. ~ ,1. < , , .J ~ • ', , •'I • J,. . , , • ~ • ~-~o!L~~r!~91P,~1?.,!~;._?,!!~J~.~-~!l~n ~!~C!iptionnt ;: •;~':t •/-~~~t,':(feet)~~ i!"~~:-f·(µg/kg) .} : , .. ,_ (ppb) :: :~'"r-'' Spirits_
1 Near tank pad -5 26584 ND 89
9-18-91 10 2868 ND 7
15 28 ND 4
20 ND ND <0.5
24 19 ND 1.
2 Near dumpster 5 15 ND <0.5
9-19-91 10 52 ND 1.1
' 15 ND ND <0.5
20 334 30 2.3
25 ND 31 <0.5
3 Near septic tank drain box 9-18-91 4 ND 16 <0.5
7 ND 31 <0.5
4 Drum area 9-20-91 7 ND ND NA
5 Soil along northerly sur1ace water runoff path 9-20-91 10 15503 ND NA
6 In culvert, before passing under tracks 9-26-91 6 ND ND NA
7 In culvert, after passing under tracks 9-26-91 6 ND ND NA
8 Drum area 10-21-91 4 and 10 ND ND <0.5
9 Along northerly runoff path 10-21-91 4 380 ND <0.5
Also detected: 22 ~~b eth11lbenzene and 74 ~"bx, lene 10 2417 ND 5.5
• TCA = 1, 1, 1-trichloroethane
BOLD-ITALICS= Samples with contaminant le~els greater than three times background.
(Source: Combined Preliminary Assessment/Site Inspection, Ram Leather Cafe, Vol. I and ll, North Carolina Department of
Environment, Health, and Natural Resources, March 1996.)
Table 2-2
Soil Samples Collected by EPA, March 1994
Ram Leather Care, Mecklenburg County, North Carolina
';:'ll••<ti::'."'"Yr•T.'~ 1l!'l' .. 1•r· --+•·a···•:?,_• .. ~., ,y•" .. -. i -·· .... -.... • •. ~im;t,1;~;Ji:~;lt'm!~~'i:,,.li~l_,;,ny:· :"·I ·-. -~ ·-:-!~~~:'A~~~ iit;,;e;sect"~ Urich!, drai~' pipe, .. s~riace water
~~;:t~~~~1~P.l~9~;" :;1~--:· ·' . :· ;r!.~!':t~,Y!9e~a!i9.n~n~!!!;_..:~-=-.~o~.north side o_t_...,;.,_:. rL!noff path,~
fu;iu1tm/Am(~l!§.~!!as~~£>H>,1~!kt:( Near drum are~i-:.:?Jf.tf~ dru_m_ areE!:_-~r~:~.: .". build_ing -. .t~~:,"' ~before culvert'
Organics µg/kg (ppb)
2-Bu1anone (MEK) ND ND
Methylene chloride 6.0 E 9.7 E
Tetrachloroethene (PCE) 32 4.2 E
Trichloroethene (TCE) 0.9 E ND
Bis(2-e1hyl hexyl)ph1halate 340 270
3,4-Methylphenol ND ND
E = Estimated value, concentration belClw the practical quantitation limit.
BOLD-ITALICS= Levels of contaminants greater than thre·e times background.
ND 66 E
8.5 E 22 E
1.1 E 21
ND ND
55 E 2300
ND. 370
(Source: Combined Preliminary Assessment/Site Inspection, Ram Leather Care, Vol. I and II, North Carolina Department of
Environment, Health, and Natural Resources, March 1996).
Ram Leather Care Superfund Sita B-1
• •
Table 5-1
1991 Bold Research Labs Soil Sample Results · .
. Ram Leather Site, Mecklenburg County, North Carolina
··t '· ' · •,,. [be'pih \ · I
' ,, .. ,J j : Soil Boring 1 .·•,•~ ;j·,t-(tt bis) ., ....
B-1
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-11
B-12
B-13
B-14
B-15,
B-16
B-17
Definitions:
bis -Below land surface
ND -Not detected
PCE -Tetrachloro8thene
TCA -1,1,1·Trichloroethane
Ram Leather Care Super/und Site
5
10
15
20
24
5
10
15
20
25
4
7
2
4 and 10
4 and 1 0
4 and 10
10 and 20
7
10
10
20
10 and 20
6
6
4 and 10
4 and 10
4
10
PCE TCA
. ~ ... (µg/kg) . (µg/kg)
26,584 ND
2,868 ND
28 ND
ND ND
19 ND
15 ND
52 ND
ND ND
334 30
ND 31
ND 16
ND 31
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
15,503 ND
ND ND
21 ND
ND ND
ND ND
ND ND
ND ND
ND ND
380 ND
2,417 ND
-~-~-Mineral Spirits·
. (mg/kg),'. :/
89
7
4
<0.5
1
89
7
4
<0.5
<0.5
<0.5
<0.5
0.5
0.5
<0.5
<0.5
NA
NA
NA
NA
NA
NA
NA
NA
<0.5
<0.5
<0.5
5.5
B-2
• •
Table 5-2
1991 Bold Research Labs Groundwater Sample Results
Ram Leather Site, Mecklenburg County, North Carolina
Pa~ameter I I ' I , 8-1· B-f,., '.MW-1 MW-2 MW-3
(µ9/L) (24 f,t) · . (25 ft) , . (32 ft) " (32 ft) (20 ft) . ..
1, 1 ·Dichloroethane 28 ND ND
1,2•Dichloroethane ND 11 ND
t-1,2-Dichloroethene 13 ND ND
Methylene chloride 78 ND ND
Tetrachloroethene (PCE) 50,060 1,201 1
1, 1, 1-Trichloroethane (TCA) 6,697 26 ND
1, 1,2-Trichloroethane 112 ND ND
Trichloroethane (TCE) 830 10 ND
Toluene 13 ND ND
Methyl-tart-butyl ether 45 ND ND
Mineral snirits lmn/L\ NA NA <0.25
Note: Groundwater samples obtained from B-1 and B-2 were collected from boreholes.
D8finitions:
NA -Not analyzed
ND -Not detected
Table 5-3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
<0.25
1994 Technical Assistance Team Soil Sample Results
Ram Leather Site, Mecklenburg County, North Carolina
I ,.,~-) Orgal'1ic$ (µg1kQ) ~?\?,)t,~t~"Ur .. ~_ l'. ~S-01 •; ! SS-02 SS-03
Acetone <DL <DL <DL
2-Butanone <DL <DL <DL
Methylene chloride 6.0 E 9.7 E 8.5 E
Tetrachloroethene (PCE) 32 4.2 E 1.1 E
Trichloroethane (TCE) 0.9 E <DL <DL
bis(2-ethylhexyl)phthalate 340 270 55 E
3,4-Meth I henol yp <DL <DL <DL
I · lnorganlcs (mg/kg) · . i' ,.,,. -' SS-01 ---· ... " SS-02 · . -SS-03 ... , ' . '
Beryllium 0.9 0.89 0:36 E
Cadmium 0.55 E <DL 0.47 E
Chromium · 46 45 27
Copper 40 40 4.9
Lead 22 24 <DL
Nickel 5.5 5 1.1 E
Selenium 10 E <DL <DL
Silver 3.2 3.9 0.9 E
Zinc 49 53 13
Definitions:
<DL -Less than instrument detection limit.
E -Estimated value; the concentration is below the practical quantitation limit.
B - , The compound was present in the laboratory blank.
Ram Leather Care Superfund Site
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
<0.25
New Well
(510 nj~,
ND
ND
ND
ND
ND
ND
ND
9
ND
ND
ND
SS-04
400 B
66 E
22 E
21
<DL
2300
370
SS-04 · .
0.58 E
<DL
89
40
22 E
6.7
<DL
2.1 E
72
B-3
• •
Table 5-4
1994 Technical Assistance Team Groundwater Sample Results
Ram Leather Site, Mecklenburg County, North Carolina
Parameter I I Parnell I. Beaver.
Glosson MW-1, MW-2 MW-3
' . (µg/L) (270 fl) . (32 fl) (32 fl) (20 fl)
cis• 1,2•Dichloroethene ND 24 4.8 ND ND ND
Tetrachloroethene (PCE) 16 7.5 24 ND ND ND
Trichloroethene (TCE\ ND 0.57 2.8 ND ND ND
Old Well
(On-site)
590
2,500
98
Note: Parnell, Beaver, and Glosson are private potable wells. Depths of the original Parnell well, the Beaver well, and the ~old~ on-
site well are unknown. Private wells at the Ivey, Tucker, Watson Body Shop, Harrah, and Scoggins properties had no detectable
voes.
Definition:
ND -Not detected
Table 5-5
1999 EPA Remedial Investigation
Volatile Organic Compound Analy1ical Results
Ram Leather Site, Mecklenburg County, North Carolina r· --· -~ · · · · ··r .. ·--· .. •·· --t · · · · · • · -• • · PW0113 ;.f~~~i.\,, i:f;i;'\ ,; ,,;: ',:,..i,':.o.woo11:" 1 Pwoo11 Pwo22 · · Pwo22B
f'~~~~;d'ar_~_!lle~er_·\~··t;~~ .. ~~Ne~~Well~ P~rnell~ Beaver _ Beaver. Glosson
F-· .,;,. ·(µg/L or ppb). ,(,, c.;, .. /Apr-99 . [ Apr-99 c ,. Aug-00 Aug-00, Aug-00
1, 1 •Dichloroethane 100 U 1.0 u 0.98 J 1.1 A 1.0 U
1,2-Dichlorobenzene 100 U 1.0 U 0.71 J 0.68 AJ 1.0 U
Chloroform 100 u 1.0 u 1.0 u 1.0 U 1.0 U
cis· 1,2·Dichloroethene 1,200 4.4 29 30 AJ 42
Tetrachloroethene (PCE) 4,000 70 14 14 AJ 100
Trichloroethane (TCEl 210 3.3 1.0 1.1 A 26
Note: The filter on the Beaver well was not functioning properly. The problem has been remedied.
Definitions:
J -Estimated value
U -Material was analyzed for but not detected. The number is the sample quantitation limit.
A -Average value
PW022B is post-filter sample
PW0089 PW00312
Tucker Ivey
Aug-00 Aug-00
1.0 u 1.0 U
1.0 U 1.0 U
0.66 1.0 U
1.0 U 3.3
1.0 U 1.0
1.0 U 1.0 U
Ram Leather Caro Suporfund Sito 8-4
0,
' V,
Table 7-1
Exposure Point Concentrations Summary
Reasonable Maximum Exposure
Ram Leather Site, Mecklenburg County, North Carolina
Chemical of
Exposure Potential Arithmetic
Point Concern Units Mean
Site Toxaphene mg/kg 0.21
Manganese mg/kg 267
Footnotes:
1 ~-~ is a result that did not require qualification.
2 95% UCL on the mean of Log-Transformed Data (95% UCL-T).
Table 7-2
Exposure Point Concentrations Summary
Reasonable Maximum Exposure
95% UCL of
Log-Transformed
Data
0.28
403
Ram Leather Site, Mecklenburg County, North Carolina
Exposure Chemical of Arithmetic 95% UCL of Log-
Point Potential Concern Units Mean Transformed Data
Tap/ Cis-1,2-µg/L NA NA
Showerhead Dichloroethene
T etrachloroethene µg/L NA NA
Trichloroethene µg/L NA NA
Footnotes:
'. Private well 0011 (the former Parnell well) is one of three private wells that had COPCs.
2 "-~ is a result that did not require qualification. -
Maximum
Scenario Timeframe: Current/ Future
Medium: Soil
Exposure Medium: Soil
.Exposure Point Concentration
Concentration/
Qualifier 1
1.3
560
Maximum
Value Units Statistic 2 Rationale
-0.28 mg/kg 95% UCL-T Reg 4 Guidance
-403 mg/kg 95% UCL-T Reg 4 Guidance
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Groundwater at Private Well 0011 1
Exposure Point Concentration
Concentration/
Qualifier' Value Units Statistic Rationale
4.4 -4.4 µg/L Maximum Reg 4 Guidance
70 -70 µg/L Maximum Reg 4 Guidance
3.3 -3.3 µg/L Maximum Reg 4 Guidance •
tJ;J
' °'
Table 7-3
Exposure Point Concentrations Summary
Reasonable Maximum Exposure
Ram Leather Site, Mecklenburg County, North Carolina
Exposure Chemical of Arithmetic 95% UCL of Log-
Point Potential Concern Units Mean Transformed Data
Tap I Cis-1,2-µg/L NA NA
Showerhead Dichloroethene
Tetrachloroethene µg/L NA NA
Trichloroethene µg/L NA NA
Iron µg/L NA NA
Manganese µg/L NA NA
Footnotes:
1 Private well 0113 (the Glosson well) is one of three private wells that had COPCs.
2 "-~ is a result that did not require qualification.
Table 7-4
Exposure Point Concentrations Summary
Reasonable Maximum Exposure
Ram Leather Site, Mecklenburg County, North Carolina
Chemical of
Exposure Potential Arithmetic 95% UCL of Log-
Point Concern Units Mean Transformed Data
Tap/ Chloroform µg/L NA NA
Showerhead
Footnotes:
1 Private well 089 (the Tucker well) is one of three private wells that had COPCs.
2 "Sis estimated value.
Maximum
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Groundwater at Private Well 01131
Exposure Point Concentration
Concentration/
Qualifier'
42 -
100 -
26 -
4,400 -
470 -
Maximum
Value Units Statistic Rationale
42 µg/L Maximum Reg 4 Guidance
100 µg/L Maximum Reg 4 Guidance
26 µg/L Maximum Reg 4 Guidance
4,400 µg/L Maximum Reg 4 Guidance
470 µg/L Maximum Reg 4 Guidance
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Groundwater at Private Well 0891
Concentration/
Exposure Point Concentration
Qualifier' Value Units Statistic Rationale
0.66 J 0.66 µg/L Maximum Reg 4 Guidance
•
•
o:! ' __,
Table 7-5
Exposure Point Concentrations Summary
Reasonable Maximum Exposure
Ram Leather Site, Mecklenburg County, North Carolina
Exposure Chemical of Arithmetic 95% UCL of Log-
Point Potential Concern Units Mean 1 Transformed Data
Tap/ 1,2-Dichloroethane µg/L 7 84
Showerhead
Chloroform µg/L 7 125
Cis-1,2-µg/L 151 2,480,889
Dichloroethene
T etrachloroethene µg/L 501 35,010,355
T richloroethene µg/L 27 2,412
Footnotes:
Maximum
Concentration/
Qualifier 2 Value
1 -1
3 -3
1,200 -1,200
4,000 -4,000
210 -210
Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Groundwater
Exposure Point Concentration
Units Statistic' Rationale
µg/L Maximum Reg 4 Guidance
µg/L Maximum Reg 4 Guidance
µg/L Maximum Reg 4 Guidance
µg/L Maximum Reg 4 Guidance
µg/L Maximum Reg 4 Guidance
1 The mean concentration can exceed the maximum concentration when one-half the sample quantitation limit is used for non-detects.
2 "-" is a result that did not require qualification. .
3 95% UCL on the mean of Log-Transformed Data (95% UCL-T).
•
•
f Table 7-6
ii" Selection of Exposure Pathways
~ Ram Leather Site, Mecklenburg County, North Carolina
I? a
i ~
0:,
' 00
-Scenario•
Timeframe
Current/
Future
Future
-
Medium
Soil
Groundwater
Soil
Groundwater
Exposure
Medium
Soil
Air
Soil
Air
Groundwater
Air
Groundwater
Air
Soil
Air
Soil
Air
Groundwater
Air
Groundwater
Air
Exposure '1 • ' ' Receptor , 1, ~
. Point Population .::Receptor Age:;
Trespasser/ Site Adolescents visitor
Site Trespasser/ Adolescents visitor
Site Worker Adult
Site Worker Adult
Private Well Resident Child
Private Well Resident Child
Private Well Resident Adult
Private Well Resident Adult
Site Resident Child
Site Resident Child
Site Resident Adult
Site Resident Adult
On-site Well Resident Child
On-site Well Resident Child
On-site Well Resident Adult
On-site Well Resident Adult
·exposure On-Site/ _ 'Typ·e of 1: 1-~: J1atiorla~~ tJ~ ,Selection o(E~c~U~u~ifot•f;
Route . . · OIi-Site· , . Analysis $-.,,a_ ~1.~ .,\,:';,-:-rt:. Expos~re Pathway_!. f·: ~.F .... ,r lt
Ingestion On-site Quant. Site visitors may incidentally ingest soil.
Dermal On-site Quant. Site visitors may come into contact with soil.
Inhalation On-site Quant._ Site visitors may inhale dust released from soil.
Ingestion On-site Quant. Site workers may incidentally ingest soil. • Dermal On-site Quant. Site workers may come into contact with soil.
Inhalation On-site Quant. Site workers may inhale dust released from soil.
Ingestion On-site Quant. Groundwater is used as a drinking water source.
Inhalation On-site Quant. Exposure to voes while showering may be a
complete exposure route.
Ingestion On-site Quant. Groundwater is used as a drinking water source.
Inhalation On-site Quant. Exposure to VOCs while showering may be a
complete exposure route.
Ingestion On-site Quant. Site residents may incide'ntally ingest soil.
Dermal On-site Quant. Site residents may come into contact with soil.
Inhalation On-site Quant. Site residents may inhale dust released from soil.
Ingestion On-site Quant. Site residents may incidentally ingest soil.
Dermal On-site Quant. Site residents may come into contact with soil. • Inhalation On-site Quant. Site residents may inhale dust released from soil.
Groundwater may be used as a drinking water Ingestion On-site Quant. source in the future.
· Inhalation On-site Quant. Exposure to VOCs while showering may be a
complete exposure route.
Ingestion On-site Quant. Groundwater may be used as a drinking water
source in the future.
Inhalation On-site Quant. Exposure to VOCs while showering may be a
complete exposure route.
Table 7-7
Cancer Toxicity Data-Oral/Dermal
Ram Leather Site, Mecklenburg County, North Carolina
Absorption Adjusted Cancer Slope Weight of Evidence/ Oral CSF: Absorption
Chemical of Potential Oral Cancer Slope Factor Efficiency (for Factor (for Dermal) 1•2 Cancer Guideline Efficiency
Concern Value Units Dermal) Value Units Description '·5 Source(s) Date(s)
1,2-Dichloroethane 9.1 E-02 I ma/ko/dav\-' 100% 9E-02 ma/ka/davl-' B2 IRIS 01/01/91
Chloroform 6.1 E-03 (mn/lm/dav)-' 100% 6E-03 ma/ka/davl-' B2 IRIS 08/26/1987
Cis-1,2-Dlchloroethene NA I mq/kq/day)-' 100% NA ma/ka/da )·' D IRIS 02/01/1995
Tetrachloroethene 5.2E-02 (malkaldav)·' 100% 5E-02 lmn/ka/da· _, w NCEA unk
Trichloroethene 1.1E-02 (mn/kn/dav)-' 100% 1E-02 lmn/ko/da _, w NCEA unk
Toxaphene 1.1E+00 (mq/kq/dav)-' 50% 2E+00 lmn/ka/dav)-' B2 IRIS 01/01/1991
Aluminum NA (mq/kq/dav)-' 20% NA lmn/ka/davl-' D NA NA
Antimony NA (ma/ka/dav)-' 20% NA mq/kq/davl-' NE IRIS 02/01/1991
Arsenic 1.5E+00 (ma/ka/dav)-' 100% 1.5E+00 ma/kq/davl-' A IRIS 04/10/1998
Barium NA I ma/ka/dav\-' 5% NA ma/kq/dav\-' D IRIS 1/21/99
Chromium NA lma/kaldav\-' 2% NA ma/ka/dav\-' D IRIS 09/03/1998
Iron NA (malkalda• . ' 20% NA malkaldav\-' D NA NA
Lead NA lmalka/da• -' 20% NA ma/kaldav\-' B2 IRIS 05/05/1998
Manaanese (soill NA (ma/kalda• -' 5% NA malkaldav)-' D IRIS 05/05/1998
Manganese (water) NA lma/ka/davl-' 5% NA ma/kalda· ' D IRIS 05/05/1998
Molybdenum NA (mq/kq/day)-' 20% NA ma/ko/da-_, NE IRIS 08/01/93
Vanadium NA (mq/kqlday)-' 3% NA lma/ko/da· _, NA NA NA
Zinc NA lmn/kn/davl-' 20% NA lma/kaldavl-' D IRIS 10/01/1992
.Notes:
1 ATSDR toxicological profiles consulted. When absorption efficiency exceeded 50% in the toxicological profile, EPA Region 4 policy is to default to 100%. Where no data were
available, the following d€faults were used: 20% inorganics, 50% semivolatiles, 80% volatiles.
2 EPA 1989. Risk Assessment Guidance for Superfund: Human Health Evaluation Manual (Part A), Appendix A, December.
3 Equation used for derivation: CSF divided by oral to dermal adjustment factor.
4 Weight of Evidence:
Known/likely
Cannot be Determined
Not Likely
5 EPA Group:
A -Human carcinogen
B 1 -Probable human carcinogen -indicates that limited human data are available
B2 -Probable human carcinogen -indicates sufficient evidence in animals and inadequate
or no evidence in humans
C -Possible human carcinogen
D -Not classifiable as a human carcinogen
E -Evidence of noncarcinogenicity
NE -Not evaluated
W -Withdrawn; Agency position pending
Acronyms:
ATSDR -Agency for Toxic Substances and Disease Registry
CSF -Cancer Slope Factor
HEAST -Health Effects Assessment Summary Tables
· IRIS -Integrated Risk Information System
NA -Not applicable
NCEA -National Center for Environmental Assessme~t
unk -Unknown
•
•
OJ '
0
Table 7-8
Cancer Toxicity Data-Inhalation
Ram Leather Site, Mecklenburg County, North Carolina
Inhalation Cancer Slope
Unit Risk Factor Weight of Evidence/
Chemical of Potential Cancer Guideline
Concern Value Units Adjustment ' Value Units Description 2'3
1,2-Dichloroethane 2.6E-05 µg/m' 3,500 9.1 E-02 (mg/kg/day)"' B2
Chloroform 2.3E-05 µgim' 3,500 '8.1E-02 (mg/kg/day)"' B2
T etrachloroethene 5.8E-07 µgim' 3,500 2.0E-03 (mg/kg/day)"' w
Trichloroethane 1. 7E-06 µgim' 3,500 6.0E-03 (mg/kg/day)"' w
Toxaphene 3.2E-04 µgim' 3,500 1.1 E+00 (mg/kg/day)"' B2
Arsenic 4.3E-03 µgim' 3,500 1.5E+01 (mg/kg/day)"' A
Chromium 1.2E-02 µgim' 3,500 4.2E+01 (mg/kg/day)"' A
Notes:
1 Adjustment: 70 kg (assumed human body weight) divided by 20 rn3/day (assumed human intake rate) multiplied by 1,000 µg/mg.
2 Weight of Evidence:
Known/Likely
Cannot be Determined
Not Likely
3 EPA Group:
A -Human carcinogen
B1 -Probable human carcinogen -indicates that limited human data are available
82 -Probable human carcinogen -indicates sufficient evidence in animals and inadequate or no evidence in humans
C -Possible human carcinogen ·
D -Not classifiable as a human carcinogen
E -Evidence of noncarcinogenicity
W -Withdrawn; Agency position pending
Acronyms:
ATSDR -Agency for Toxic Substances and Disease Registry
HEAST -Health Effects Assessment Summary Tables
IRIS -Integrated Risk Information System
NCEA -National Center for Environmental Assessment
unk -Unknown
Source(s) Date(s)
IRIS 01/01/1991
IRIS 08/26/1987 • NCEA unk
NCEA unk
IRIS 01/01/1991
IRIS 04/10/1998
IRIS 09/03/1998
•
f Table 7-9
i Non-Cancer Toxicity Data-Inhalation
f Ram Leather Site, Mecklenburg County, North Carolina ., • l Inhalation RIC Adjusted RID 1 Combined RIC: Target Organ(s) Chemical of Potential Chronic/ Primary Target Uncertainty/
Concern Subchronic Values Units Values Units Organ Modi" inn Factors Source(s) Date(s)
i Barium Chronic 5E-04 mg/m3 1 E-04 mg/kg/day Fetus 1000 HEAST 1997
Chromium Chronic 1 E-04 mg/m3 3E-05 mg/kg/day Lung 300 IRIS 09/03/1998
Manganese (soil) Chronic 5E-05 mg/m3 · 1 .4E-05 mg/kg/day CNS 1000 IRIS 05/05/1998
. • Notes:
1 Equation used for derivation: AfC divided by 70 kg (assumed human body weight) multiplied by 20 m3/day (assumed human intake rate).
Acronyms:
CNS -Central nervous system
HEAST -Health Effects Assessment Summary Tables
IRIS -Integrated Risk Information System
NCEA -National Center for Environmental Assessment
RfC -Reference concentration
RfD -Reference dose
unk -Unknown
•
t:,:, '
tI:l ' N
Table 7-10
· Non-Cancer Toxicity Data-Oral/Dermal
Ram Leather Site, Mecklenburg County, North Carolina
Oral RID Absorption Dermal RfD 2•3 Combined RID: Target Organ(s) Chemical of Potential Chronic/ Efficiency {for Primary Target Uncertainty/
Concern Subchronic Value Units Derman 1 Value Units Organ(s) Modifvinn Factors Source{s) Date(s)
1,2-Dichloroethane Chronic NA mq/kq/dav 100% NA mq/kq/dav NA NA IRIS 01/01/1991
Chloroform Chronic 1E-02 mq/kq/dav 100% 1E-02 mQ/kq/dav Liver 1000 IRIS 12/02/1985
Cis-1,2-Dichloroethene Chronic 1E-02 mo/ko/dav 100% 1E-02 moiko/dav Deer. hemaocrit, hemoqlobin 3000 HEAST 1997
T etrachloroethen·e Chronic 1E-02 mo/ko/dav 100% NA mnllrn/dav Liver 1000 IRIS 03/01/1988
Trichloroethene Chronic NA ma/ka/dav 50% NA ma/ka/dav NA NA IRIS 08/01/1992
Toxaohene Chronic NA mg/kg/day 50% NA mg/kg/day NA NA IRIS 01/01/1991
Aluminum Chronic 1E+00 mq/kq/day 20% 2E-01 mq/kq/day CNS (Neura1axici1y) 100 NCEA 08/13/1999
Antimony Chronic 4E·04 · mg/kg/day 20% 8E-05 mg/kg/day Longevity, blood glucose, 1000 IRIS 02/01/1991
cholesterol
Arsenic Chronic 3E-04 mg/kg/day 100% 3E-04 mg/kg/day Skin (Hyperpigmentation, 3 IRIS 04/10/1998
keratosis)
Barium Chronic 7E-02 mg/kg/day 5% 4E-03 mg/kg/day No adverse effect 3 IRIS 1/21/99
Chromium Chronic 3E-03 mg/kg/day 2% 6E-05 mg/kg/day No adverse effect 900 IRIS 09/03/1998
Iron Chronic 3E-01 mq/kq/dav 20% 6E-02 mq/kq/dav No adverse effect 1 NCEA 1999
Lead Chronic NA mq/kq/dav 20% NA mo/ko/dav CNS (Neurotoxicitv) NA NA NA
Manqanese (soil) 4 Chronic 7E-02 mo/ko/dav 5% 4E-03 mo/ko/dav CNS (Neurotoxicitv) 3 Reaion 4 1995
Manqanese (water) 4 Chronic 2.4E-02 mo/ko/dav 5% 1E-03 ma/ka/dav CNS (Neurotoxicitv) 3 Reaion 4 1995
Molvbdenum Chronic 5E-03 ma/ka/dav 20% 1E-03 mg/kg/day Increased uric acid levels 30 IRIS 08/01/1993
Vanadium Chronic 7.0E-03 mg/kg/day 3% 2E-04 mg/kq/day Decreased hair cystine unk HEAST 1997
Zinc Chronic 3E-01 ma/ka/dav 20% 6E-02 mn/kn/dav Decreased ESOD 3 IRIS 10/01/1992
Notes:
1 ATSDR toxicological profiles cc;insulted. When absorption efficiency exceeded 50% in the toxicological profile, EPA Region 4 policy is to default to 100%. Where no data were
available, the following defaults were used: 20% inorganics, 50% semivotatiles, 80% volatiles.
2 EPA 1989. Risk Assessment Guidance for Superfund: Human Health Evaluation Manual (Part A), Appendix A, December.
3 Equation used for derivation: RfD x oral to dermal adjustment factor.
4 The RfD for manganese in IRIS is 1.4E-1 mg/kg/day based orl the NOAEL of 10 mg/day. For soil exposure, Region 4 policy is to subtract the aVerage daily dietary exposure
(5 mg/day) from the NOAEL to determine a ~soil" RfD. When this is done, a ~soir RfD of7E-2 mg/kg/day results. For water, a neonate is considered a sensitive receptor for the
neurological effects of manganese. Thus, caution (in the form of a modifying factor) is warranted until more data are available. Using a modifying factor of 3 results in a "water'' RfD
af 2.4E-2 mg/kg/day.
Acronyms:
ATS DR -Agency for Toxic Substances and Disease Registry
ESOD -Erythrocyte superoxide dismutase
HEAST -Health Effects Assessment Summary-Tables
IRIS -Integrated Risk Information System
NA -Not applicable
NCEA -National Center for Environmental Assessment
RfD -Reference dose
unk -Unknown
•
•
Table 10-1
Summary of Soil Alternatives Evaluation
Ram Leather Site, Mecklenburg County, North Carolina
Threshold Criteria Balancing Criteria
Implementability
Estimated Time Cost
Overall Protection of Long-Term Technical/ for Approx.
Remedial Human Health and Compliance with Effectiveness and Reduction of MITN Short-Term Engineering Implementation Total Present
Alternative the Environment ARARs Permanence Through Treatment Effectiveness Considerations (years) Worth
1 -No Action Does not timit Chemical-specific The contaminated No reduction of MfTN Level D protective None <1 $21,000
migration of or ARARs are not met. material is a long-term is realized. equipment is required • remove contaminants. Location-and action-impact. The during sampling.
specific ARARs do remediation goals are
not apply. not met.
2 -In Situ Removes All action-specific No residual risks from Reduction of MITN Level C and D Good 5 $1.15 million
Treatment with contamination, ARARs are expected the alternative. through treatment is protective equipment understanding
Soil Vapor thereby protecting to be met. Location-Groundwater is realized. required during site of site geology/
Extraction groundwater. specific ARARs are further protected by activities. Noise hydrogeology is
applicable and would the treatment of nuisance from use of required.
need to be met. subsurface soil. heavy equipment
{well installation).
3 -Excavation, Removes ARARs are met No long-term public Only reduction of Level C and D Minimal 1 $1.15million
Off-site contamination from through excavation health threats would mobility would be protective equipment technical or (Subtitle D)
Transportation site, thereby and off-site disposal exist related to soils. achieved by off-site required during site engineering $2.15 million
and Disposal at protecting of soil. Groundwater would disposal. activities. Excavating requirements (Subtitle C)
· Subtitle C or D groundwater. also be protected and grading may except for
Landfill through removal of result in potential installation of
source contaminants. release of dust. railspur and
Noise nuisance from proper
use of heavy manifesting of
equipment. shipments. •
Table 10-2
Summary of Groundwater Alternatives Evaluation
Ram Leather Site, Mecklenburg County, North Carolina
Threshold Criteria Balancing Criteria
Implementability .
Estimated Time Cost
Overall Protection of Long-Term Technical/Engi for Approx.
Remedial Human Health and Compliance with Effectiveness and Reduction of MfTN Short-Term neering Implementation Total Present
Alternative the Environment ARARs . Permanence Through Treatment Effectiveness Considerations (years) Worth
1 -No Action Does not limit Chemical-specific The contaminated No reduction of M/TN Level D protective None <1 $32,000
migration of or ARARs are not met. groundwater is a long-is realized. equipment is required • remove contaminants. Location-and action-term impact. The during sampling.
Regular private well specific ARARs do remediation goals and
monitoring reduces not apply. MCLs are not met.
risk.
2-Pump and Reduces Chemical-specific Long-term public Mobility, toxicity and Level C and D Treatability 5 $1.01 million
Treat with contamination and ARARs are met near health threiats volume are reduced. protective equipment study may be
Biological further migration. the source of associated with required during site needed.
Treatment and Regular private well contamination. groundwater are activities.
Groundwater monitoring reduces Location-and action-reduced.
Monitoring risk.· specific ARARs are
applicable and would
need to be met.
3-Pump and Reduces Chemical-specific Long-term public Mobility, toxicity and Level C and D Treatability 5 $926,000
Treat With contamination and ARARs are met near health threats volume are reduced. protective equipment study may be
Physical and/or eliminates further the source of associated with required during site needed.
Chemical migration. Regular contamination. groundwater are activities.
Treatment and private well Location-and action-reduced.
Groundwater monitoring reduces specific ARARs are
Monitoring risk. applicable and would
need to be met.
0:,
'
• •
Table 12-1
Detailed Interim Remedy Cost Estimates
Alternative 3 (Soil) -Excavation, Off-site Transportation, PRESENT WORTH COST
and Disposal at Subtitle D Landfill
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Tota.I Cost
Item Description Units Quantity Dollars Dollars
MOBILIZATION/DEMOBILIZATION
Transport Equipment & Staff each 1 $40,000 $40,000
Temporary Facilities each 1 $40,000 $40,000
EXCAVATION
Soil Excavation cy 3,500 $10 $35,000
Dust Control & Placement in Storage Area cy 3,500 $10 $35,000
Backfill Excavated Areas with Clean cy 3,500 $10 $35,000
Fill/Treated Soil
Grading & Compacting acre 0.5 $5,000 $2,500
Seed & Mulch acre 0.5 $2,000 $1,000
OFF-SITE LANDFILLING
Truck Transport truckload 195 $700 $136,500
Disposal at Subtitle D Landfill ton 3,500 $65 $227,500
EQUIPMENT & MATERIALS
Health & Safety Equipment each 1 $40,000 $40,000
Subtotal -Capital Cost $592,500
Contractor Fee ( 10% of Capital Cost) $59,250
Legal Fees, Licenses & Permits (5% of Capital Cost) $29,625
Engineering & Administrative (15% of Capital Cost) $88,875
Subtotal $770,250
Contingency {25% of Subtotal) $192,563
TOTAL CONSTRUCTION COST $962,813
PRESENT WORTH O&M COST $188,084
TOTAL PRESENT WORTH COST $1,150,897
Alternative 3 {Soil) -Excavation, Off•site Transportation, OPERATION & MAINTENANCE COSTS
and Disposal at Subtitle D Landfill
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Total Arinual Operation
Item Description Units Quantity Dollars Cost, Dollars Time, Years
PRE-LANDFILL MONITORING
Soil Sample Analyses week 52 $2,000 $104,000 1
EXCAVATION MONITORING
Confirmatory Sample Analyses samples 10 $500 $5,000 1
AIR QUALITY MONITORING week 52 $1,000 $52,000 1
SUBTOTAL $161,000
CONTINGENCY (25% of Subtotal) $40,250
TOTAL $201,250
This option assumes that soil would be characterized as nonhazardous and would require no treatment prior to disposal.
Estimated acreage requiring remediation: 0.5 acres
1ton=1cy
Assumes transport of 18 tons/truck load and availability of a disposal laciiity within 350 miles.
Transportation and disposal costs developed from R.S. Means 1999.
Ram Leather Care Superfund Site
Present
Worth '
$97,196
$4,673
$48,598
$150,467
$37,617
$188,084
B-15
• •
Table 12-2
Detailed Interim Remedy Cost Estimates
Alternative 3 (Soil) -Excavation, Off-site Transportation! PRESENT WORTH COST
and Disposal at Subtitle C Landfill
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Total Cost
Item Description Units Quantity Dollars Dollars
MOBILIZATION/DEMOBILIZATION
Transport Equipment & Staff each 1 $40,000 $40,000
Temporary Facilities each 1 $40,000 $40,000
EXCAVATION
Soil Excavation cy 3,500 $10 $35,000
Oust Control & Placement in Storage Area cy 3,500 $10 $35,000
Backfill Excavated Areas with Clean cy 3,500 $10 $35,000
Fill/Treated Soil
Grading & Compacting acre 0.5 $5,000 $2,500
Seed & Mulch acre 0.5 $2,000 $1,000
OFF-SITE LANDFILLING
Truck Transport truckload 195 $700 $136,500
Landfill Hazardous Solid Bulk Waste ton 3,500 $241 $843,500
Requiring Sta~ilization
EQUIPMENT & MATERIALS
Health & Safety Equipment each 1 $40,000 $40,000
Subtotal -Capital Cost $1,208,500
Contractor Fee (10% of Capital Cost) $120,850
Legal Fees, Licenses & Permits (5% of Capital Cost) $60,425
Engineering & Administrative (15% of Capital Cost) $181,275
Subtotal $1,571,050
Contingency (25% of Subtotal) $392,763
TOTAL CONSTRUCTION COST $1,963,813
PRESENT WORTH O&M COST $188,084
TOTAL PRESENT WORTH COST $2,151,897
Alternative 3 (Soil) -Excavation, Off-site Transportation, OPERATION & MAINTENANCE COSTS
and Disposal at Subtitle C Landfill
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Total Annual Operation Present
Item Description Units Quantity Dollars Cost, Dollars Time, Years Worth
PRE-LANDFILL MONITORING
Soil Sample Analyses week 52 $2,000 $104,000 1 $97,196
EXCAVATION MONITORING
Confirmatory Sample Analyses samples 10 $500 $5,000 1 $4,673
AIR QUALITY MONITORING week 52 $1,000 $52,000 1 $48,598
SUBTOTAL $161,000 $150,467
CONTINGENCY (25% of Subtotal) $40,250 $37,617
TOTAL $201,250 $188,084
This option assumes that soil would be characterized as hazardous and would require treatment prior to disposal in Subtitle C landfill.
Estimated acreage requiring remediation: 0.5 acres
11on=1cy
Assumes transport of 18 tons/truck load and availability of a disposal facility within 350 miles.
Transportation and disposal costs developed from .R.S. Means 1999.
Ram Leather Care Superfund Site B-16
• •
Table 12-3
Detailed Interim Remedy Cost Estimates
Alternative 3 (Groundwater) -Pump and Treat with PRESENT WORTH COST
Physical or Chemical Treatment
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Total Cost
Item Description Units Quantity Dollars Dollars
MOBILIZATION/DEMOBILIZATION lump sum 1 $40,000 $40,000
ADDITIONAL DATA COLLECTION
Pump and Treat (Existing Wells) lump sum 1 $20,000 $20,000
Additional Groundwater Data Colle~tion lump sum 1 $20,000 $20,000
TREATABILITY STUDY lump sum 1 $40,000 $40,000
TREATMENT SYSTEM
Treatment Components (air stripping towers, lump sum 1 $25,000 $25,000
carbon adsoprtion, packing, etc.)
System components (piping, electrical , lump sum 1 $13,400 $13,400
installation, etc.)
Buildinnttank nads lumn sum· 1 $148,000 $148,000
Subtotal -Capital Cost $306,400
Contractor Fee (10% of Capital Cost) $30,640
Legal Fees, Licenses & Permits (5% of Capital Cost) $15,320
Engineering & Administrative (15% of Capital Cost) $45,960
Subtotal $352,360
Contingency (25% of Subtotal) $88,090
TOTAL CONSTRUCTION COST $440,450
PRESENT WORTH O&M COST $485,361
TOTAL PRESENT WORTH COST $925,811
Alternative 3 (Groundwater) -Pump and Treat with OPERATION & MAINTENANCE COSTS
Physical or Chemical Treatment
Discount Rate: 7%
Site Name: Ram Leather Site
Site Location: Mecklenburg County, North Carolina
Unit Price Total Annual Operation Present
Item Description Units Quantity Dollars Cost, Dollars Time, Years Worth
QUARTERLY GROUNDWATER
MONITORING
Personnel (2-man crew @ 3 12-hour days) hours 288 $50 $14,400 5 $59,043
Supplies/ Travel days 8 $3,000 $24,000 5 $98,405
Groundwater Sampling and Lab Testing sample 20 $500 $10,000 5 $41,002
Report Preparation lump sump 4 $4,000 $16,000 5 $65,603
TREATMENT SYSTEM OPERATION &
MAINTENANCE
Operation year 1 $7,000 $7,000 5 $28,701
System Inspections inspection 52 $400 $20,800 5 $85,284
Svstem Renlacement svstem 1 $2,500 $2,500 5 $10,250
O&M SUBTOTAL $94,700 $388,289
Contractor Fee (10% of O&M cost) $9,470 $38,829
Legal Fees; Licenses & Permits (5% of O&M Cost) $474 $1,941
CONTINGENCY (25% of Subtotal) $23,675 $97,072
SUBTOTAL $118,375 $485,361
Costs are based on use of existing wells ,treatment with an air stripping system, and a treatment duration of 5 years. Groundwater
modeling and treatability studies completed for the design of a pump and treat system will determine if, and in what time frame a
pump-and-treat remediation can achieve remediation goals for the site.
Costs for treatment system components obtained from R.S. Means Environmental Remediation Cost Data-Assemblies (1999). Costs
for other system components were calculated as a percentage (67%) of treatment system components.
Treatment system operation and maintenance costs are based on waste disposal, pump replacement, tower packing, electricity
quantities and costs estimated from 1999 Means data.
Ram Leather Care Superfund Site B-17
00
Table 13-1
Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
Ram Leather Site, Mecklenburg County, North Carolina
• ··••-.;,. • •"" · · · ~ -• --~-..... ;, .:r .• ,,.J:"'•-tf;r-=-·--.,-..,•--.• .,,. ,;...1lra.~----::~ ~.:Standard, Requirement Criteria, or; t; , 1~~~; ~1; c·~ 1: !::; ?1' ..... : : • ! :;,-.;;~,:. -.~: · ~J•SZfi. ,st~* P.~;~j;e;:.~.:g~~ijVApplic8ble Or Rtilevant~ .,-., -'i: . ,. • • •. • , • • . .,.._, ·-i .,t.i .. 1,.-1 a Ion,.,,,·_·r' • . ~·-J.t~· :; ....... ?j' escrip I0n -.. ::: ..... i-::fri,.,..,~~ t-:..'-....~ "'r--f '"'i ~· ="'.'"r -~l .!!-.._ ~-, , -L1'!11tat1on t• --,1 .t!l~-::·-,~t;Jtf~ .. -.• "'"f! :-~ :+-· .. ·;.··.•-"':..-:!:f .. ·•• ,;~_M-"!..._~·A1~:-~--~~Wtp;_!~-af!(!ApP.r?p_rJa~e~.~"'"-
Contaminant-Specific ARARs
Clean Air Act 42 USC§ 7409
National Primary and Secondary Ambient Air 40 CFR Part 50 Air quality levels that protect public health Applicable
Quality Standards
Resource Conservation and Recovery Act
Identification and Listing of Hazardous Waste 40 CFR Parts 262-265 and Defines those solid wastes that are subject to Applicable
Parts 124, 270, and 271 regulation as hazardous wastes under 40 CFR
Parts 262-265, 124,270, and 271
Clean Water Act 33 USC§ 1251-1376
Water Quality Criteria 40 CFR Part 131 Quality Criteria Sets criteria for water quality based on toxicity Applicable
for Water 1976, 1980, 1986 to aquatic organisms and human health
NPDES 40 CFR Part 122 General permits for discharge from Relevant and Appropriate
construction
Dredge and Fill Requirements [Section 40 CFR Part 230 Action to prohibit discharge of dredged or fill .Relevant and Appropriate
404(b)(1)) material into wetland without permit.
Safe Drinking Water Act 40 USC§ 300
National Primary Drinking Water Standards 40 CFR Part 141 Establishes health-based standards for public Relevant and Appropriate
water systems (maximum: contaminant levels)
National Secondary Drinking Water 40 CFR Part 143 Establishes welfare-based standards for public Relevant and Appropriate
Standards water systems (secondary maximum
contaminant levels)
•
•
0:,
'
Table 13·2
Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
Ram Leather Site, Mecklenburg County, North Carolina
-:. Standard, Requirement ·critE!ri0, or :r ~ '# ';~;t? !fl ;, Ii---:: :--:~.-~~_-::~::-.rt ·· ......... ·--'•-?·~""--"'~ijr;,~-... !~,.i-.. !,<"',-',Utf'Rl:'"•··' ~p:,.lii' ··-' i-~,..,.,_ .. 1:_ .... -~· •·"'.! ~~~ '~ ,A-pplicable Or1AelE!vant) dtation · ~ Limitation i 1 : • ; ,;, -~,Des;np_t•r~; --.~--h. ~¥: ix~(J.}~;~j im~I_ApprgPriffe1~~~~: '. ~-~-,--?-#•
Location-Specific ARARs
National Historic Preservation Act 16 USC § 470; 36 CFR Part 800 Requires federal agencies to take into account Applicable
the effect of any federally-assisted undertaking
or licensing on any district, site, building,
structure, or object that is included in, or
eligible for, inclusion in the National Register of
Historic Places.
Archeological and Historic Preservation Act 16 USC§ 469; 40 CFR § Establishes procedures to preserve historical Applicable
6.301 (c) and archeological data that might be destroyed
through alteration of terrain as a result of a
federal construction project or a federally
licensed activity or program.
FloodQlain Management Executive Order Executive Order 11988 Action to avoid adverse effects, minimize Applicable
potential harm, and restore and preserve
natural and beneficial values of the floodplain.
Wetlands Management Executive Order Executive Order 11990 Action to minimize the destruction, loss or Applicable
degradation of wetlands.
Protection of Wetlands and FloodQlains 40 CFR Part 6, Appendix A Contains EPA's regulations for implementing Applicable
Executive Orders 11988 and 11990.
Historic Sites, Buildings and Antiguities Act 16 USC§§ 461-467; 40 CFR Requires federal agencies to consider the Applicable
§ 6.301 (a) existence and location of landmarks on the
" National Registry of Natural Landmarks to
avoid undesirable impacts on such landmarks
Endangered SQ:ecies Act 16 USC§§ 1531; 40 CFR Part Requires action to conserve endangered Applicable
6.302; 50 CFR Part 402 species within critical habitat upon which
species depend; includes consultation with the
Department of the Interior
•
•
to
' N 0
Table 13-3
Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
Ram Leather Site, Mecklenburg County, North Carolina
.,: • ' • -• • ··~·. ,JI-~ ... -~ -1~9.l~ ~1 ~ 1,1 ... ' • I •' • C,!.' .•. , ~---· =r· .-rry .... w-" ';'t:i:,•~.:.i:,lr..-f,ui-~ hi•tf--~•F •h•;'S·.;,~, }-;· , Standard, Requirement Criteria, or jb~) :gf.~hi"t 6•-rt~""tt·· r~ir,'4~-f:. :· t· ' . .!~:f_,~,:~;t,.·![):-~•-e,._..,,i·••.,.,,:1g~~~~-~~-\;~ .. s APplicabltfil/~elevantjf
•• {' ., • , ·• • , ... 'rt-t.•t.,_r•• ,.,!..;. it-I 8 10n ... , ,i .. ' ·--... , .. 1--.: • • ~ escr1p 10n ~~~-··''./["''!? l•,·')t~~ ... ~'! •• , -""""'·JS~-, ·~. 1.!~:·.· .. : •-umitation ·, :~-~ .. 1"!'j,-..:-.;;::t~.J;s!J: 1· •,· .. 1 ....... f ··_. , :-.'t_:.:•:-~:;-r•::-.,.·t!rA1::_~~<!'.~~.::";.;J~:":~•i:-:-',;~~-;l~~;JiaQd_Appr(?P!~~t~f-.:C
Fish and Wildlife Coordination Act 16 USC§§ 661-666c Any federal agency which proposes or Applicable
authorizes a modification to a stream, or water
body which may affect fish and wildlife must
consult with the Fish and Wildlife Service. This
act requires protection of fish and wildlife
resources.
Migrato!]£ Bird Treaty Act of 1973 1e use§§ 703 Established a prohibition, unless permitted, to Applicable
pursue, hunt, capture, kill, or take any
migratory bird or attempt any of these actions.
Also protects migratory birds in their
environments.
Emergency Wetlands Resources Act of 1986 Requires the Secretary to establish a National Applicable
Wetlands Priority Plan and report to Congress
on the loss of wetlands including the role
federal agencies have in the loss of these
wetlands.
U.S. Fish and Wildlife Service Mitigation Provides for the policy to develop consistent Applicable
Policy and effective recommendations to protect and
conserve natural resources. Also allows
federal and private developers to incorporate
mitigation measures into the early stages of
planning.
National Environmental Policy Act of 1969 Requires federal agencies to prepare Applicable
comprehensive environmental impact
statements for every recommendation on
proposals for legislation and federal actions
which might significantly affect the quality of
the enVironmSnt.
Resource Conservation and Recove!Y Act 40 CFR Part 264 Requires hazardous waste facilities to be (1) Relevant and Appropriate
located at least 200 feet from a fault and (2)
designed to withstand a 100-year flood if
located in the 100-year floodplain.
•
•
f Table 13-4
ii" Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
f Ram Leather Site, Mecklenburg County, North Carolina .,
a
I ~
o:l ' N
Hazardous Materials Transportation Act
Hazardous Materials Transportation
Regulations
Resource Conservation and Recovery Act
Criteria for Classification of Solid Waste
Disposal Facilities and Pi-actices
Standards Applicable to Transporters of
Hazardous Waste
Standards for Owners and Operators of
Hazardous Waste Treatmen_t, Storage, and
Disposal Facilities
Action-Specific ARARs
49 USC§§ 1801-1813
49 CFR Parts 10, 171-177
40 CFR Part 257
40 CFR Part 263
40 CFR Part 264
Regulates transportation of hazardous ·
i:naterials
Establishes criteria for use in determining
which solid waste disposal facilities and
practices pose a reasonable probability of
adverse effects on health or the environment
and thereby constitute prohibited open dumps
Establishes standards that apply to persons
transporting hazardous waste within the U.S. if
the transportation requires a manifest under 40
CFR
Part 262
Establishes minimum national standards which
define the acceptable management of
hazardous waste for owners and operators of
facilities which treat, store, or dispose _of
hazardous waste
Applicable •
Relevant and Appropriate
Applicable
Relevant and Appropriate •
f Table 13-5
m Summary of Potential Federal Applicable or Relevant and Appropriate Requirements
f · Ram Leather Site, Mecklenburg County, North Carolina
" a
"' ~
i
~
~ : . -.J -~t~ndard, R~quire~ent Cri·t~!ia,· ~'~ ~t ;q -~}lf .. : :~ t ; c·t r' € ~j~ --~ .~r -}' ·r-1 -· • s:~ L" .• f ~, ~-h~i..-•• 11 T~~ -~. •J I 8 10n •+ • -'t • _. r-:; • -.: . 1m1 a 10n · · -· • .,•.·:--•.. ··: • r:-• .. • h ,:.. •.
Clean Water Act 33 use§ 1342
NPDES 40 CFR Part 122
Dredge and Fill Requirements [Section 40 CFR Part 230
404(b)(1 )I
Occug:ational Safetl'.'. and Health 29 CFR 1910
Administration Reguirements
Notes:
-9ode of Federal Regulations CFR
NPDES
USC
-National Pollutant Discharge Elimination System
-United Stated Code
• "• -· ,t ·J• • ... ~ 1-• .--.--"~1:_,..., ;•; ••••,.le..£<-H:-,_;•41,-t,:...-r-"'r!; -. -.. -:-.l: re kl.!\: -ti:..!, --~~.t,:=·-.:i!~!-lrAp~licable~or, ReleVantfl .·•r::-;~:-.s:;:::s.-.. ·~ escnp ion.,,...~~~-.. :··---~ !=f! .... ~tafldAPPrOP-fiSte·~"ti ·~;-J;,:;.·."':_.;.~ ~"I, •.• ~;.~-...;,·::-~-... :.~;; •·?~·· ~ ... -;ct
Requires permits for the discharge of Relevant and Appropriate
pollutants from any point source into waters of
the United States
Relevant and Appropriate
Action to prohibit discharge of dredged or fill
material into wetland without permit.
E::,tablishes requirements for workers at Applicable .
remedial action sites. Any remedial action on-
site must be performed in accordance with
applicable OSHA standards.
•
•
f Table 13-6
[ Summary of Potential State Applicable or Relevant and Appropriate Requirements
~ Ram Leather Site, Mecklenburg County, North Carolina
i r i!-,
Q
~
0, ' N t,J
,,,, •.•. ' . , ,--•-._. ,l '',f;f'·j'."f' .;:,,:1 .. .__ .. tt:-;f r:-.-.;·.;,,-. , ... ~,. -r _.,..,..,..,,.·"!;·<£3~Jt•~-•~-q::.';•H.#"-~ij-·•1f-..,_H_;~...._...s.:•~J-;p•,,.1,Ff~.rj-f
• ~ Standard, Requirement Criteria, or. I:• : ~ ~-Ht~~~f_,fi-t:-C{ ~t".--r. _!1~!.~;,µ~?3,-.,: .. ~ ... b.;z_ .. 't; ~r[). ~ .i __ f:'"~';f~~t-~ ~~i!i?Applicable.oriRelevant:?, •• :-· •-.• •• ••• • ..__ , . t_,,.• -· .. -,..r.,~e-1 .. ~i·-1 a 1on;i-.. p~~:;+--=;;~ ·--·= ~ ~---,:::_ ... escr1p 10n ·~-~ .. ;.-.g r:, ........ ~ .. ~ .. --~,i':.---k"';"-l"~•a:~ .!-,}-:~.: :-• ~ : .... .: . L1m1tat1on;: ' ;; ! 1~ _:'t' ;e.~~:y~a2-;t;;:ji;:::t, _,;. --tijfi·:..~i; _p.~.!:tE;:'.i~~r~•-f;af ~r-"P~• .. '!~-~?-~~?.!~.\~ ~:, --~:.1;,~If\.and_AppJ0pr1~t~,..i-
Contaminant-Specific ARARs
North Carolina Environmental Management Title 15A Chapter 2 .
Ambient Air Quality Standards 15A 20.0400 Air quality standards protective of the public Applicable
health
Emission Control Standards 15A 2D 0501 -0541 Regulates emissions by providing control Applicable
standards
Surface Water and Wetland Standards 15A2B Provides surface water quality standards Applicable
including assignment of stream classifications,
effluent limitations and reporting requirements
for surface water monitoring
Groundwater Classification and Standards 15A 2L Provides groundwater classification and quality Applicable
standards
Location -Specific ARARs
North Carolina Solid Waste Management Title 15A Chapter 13B Provides requirements for the storage, Applicable
collection, transportation, separation,
processing, recycling, recovery and disposal of
solid waste
Action-Specific ARARs
North Carolina Solid Waste Management 15A Chapter 13B Establishes specific requirements for the Applicable
operation and maintenance of solid waste
landfill disposal sites.
15A 13B.0300 Provides requirements for solid waste Applicable
treatment and processing facilities.
15A 13B.1600 Provides requirements for municipal solid Applicable
waste landfill facilities
•
Table 13-7
Summary of Potential State Applicable or Relevant and Appropriate Requirements
Ram Leather Site, Mecklenburg County, North Carolina
North Carolina Hazardous Waste
Management
North Carolina Environmental Management
15A Chapter 13A
15A 13A.0107
15A 13A.0108
15A 13A.0111
15A 13A.0112
15A Chapter 2
Provides rules for the management of
hazardous wa.Ste.
Provides standards applicable to the
generators of hazardous waste
Provides standards applicable to the
transporters of hazardous waste
Provides standards for the management of
specific hazardous wastes and specific types
of hazardous waste man?gement facilities.
Establishes requirements for wastes that can
be and cannot be land disposed. ·
Relevant and Appropriate
Relevant and Appropriate •
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
•
· ~ Table 13-8 3 ii Summary of Potential State Applicable or Relevant and Appropriate Requirements
f Ram Leather Site, Mecklenburg County, North Carolina ., • t
~ North Carolina Environmental Management
North Carolina Sedimentation Control
15A2B
15A2D
15A2H
15A 2K
15A 2R
15A4B
Provides surface water quality standards
including assignment of stream classifications,
effluent limitations and reporting requirements
for surface·water monitoring
Air pollution contra:! air quality and emissi_ons
standards
Regulates point source discharges to surface
waters
Provide~ requirements related to dam safety
Requirements related to wetlands restoration
Requirements related to control of
sedimentation and minimizing erosion.
Persons engaging in land disturbing activities
shall take all reasonable measures to protect
public and private property from those
activities.
Applicable
Applicable
Applicable
Relevant and Appropriate
Relevant and Appropriate
Applicable
•
•
• •
Appendix C
Proposed Plan Fact Sheet
• •
Appendix D
Responsiveness Summary
• •
Comments provided by concerned citizens in the vicinity of
the Ram Leather Care Site
Citizens in the vicinity of the Ram Leather Care Site are concerned about the health effects related
to the contamination at the site. We would like have our wells tested and be informed about all site
activities.
Response:
EPA will conduct a clean-up action to prevent further contaminants from migrating from the site.
Residential wells will be sampled this Fall 2004 by EPA' s Science and Ecosystem Support Division
in Athens, Georgia. EPA will continue collecting additional data to characterize the site and monitor
the groundwater. The citizens will be informed of all activities at the site. Sampling results will be
forwarded to the residents.
Comments provided by Mecklenburg County Land Use and Environmental
Services Agency (LUESA)
Mecklenburg County believes that insufficient data has been collected to design a pump and treat
system. LUESA suggest that EPA conduct a 24-hour pump test and provide a comprehensive
schedule for system maintenance, groundwater monitoring and remediation progress reports.
LUESA also suggest that EPA conduct confirmatory soil sampling following excavation.
Response:
EPA will conduct a 24-hour pump test to aid in treatment design. A schedule for groundwater
monitoring and remediation progress reports, and system maintenance will be submitted to the State
of North Carolina for review. Confirmatory soil sampling will be conducted to ensure that the soil
remediation goals are met.
• •
Appendix E
State Concurrence Letter