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HomeMy WebLinkAboutNCD986187094_19970113_Reasor Chemical Company_FRBCERCLA FS_Draft Work Plan - RI FS Project Assistance (Revision 0)-OCRu 0 D 0 D 0 D D D D D 0 0 0 u D D D D Document Control No. 4400-45-AGBY Revision 0 DRAFf WORK PLAN REMEDIAL INVESTIGATION/FEASIBILITY STUDY PROJECT ASSISTANCE REASOR CHEMICAL COMPANY SITE CASTLE HAYNE, NEW HANOVER COUNTY, NORTH CAROLINA Work Assignment No. 77-4Rl24 JANUARY 1997 REGION IV U.S. EPA CONTRACT NO. 68-W9-0057 Roy F. Weston, Inc. 1880-H Beaver Ridge Circle Norcross, Georgia 30071 WESTON W.O. No. 04400-077-096-0001-00 I a u ·D ·D E I. I I I I I I I I I I I I Document Control No. 4400-45-AGBY Revision 0 DRAFT WORK PLAN REMEDIAL INVESTIGATION/FEASIBILITY STUDY PROJECT ASSISTANCE REASOR CHEMICAL COMPANY SITE CASTLE HAYNE, NEW HANOVER COUNTY, NORTH CAROLINA Work Assignment No. 77-4RI24 JANUARY 1997 REGION IV U.S. EPA CONTRACT NO. 68-W9-0057 Roy F. Weston, Inc. 1880-H Beaver Ridge Circle Norcross, Georgia 30071 WESTON W.O. No. 04400-077-096-0001-00 RECEIVED 'JAN 2 4 1997 SUPERFUND SECTION D D D I I I I I I I I I I I Technical Review Perfom1ed by: DRAFT RI/FS WORK PLAN REVISION 0 RI/FS PROJECT ASSISTANCE REASOR CHEMICAL COMPANY SITE CASTLE HAYNE, NORTH CAROLINA U.S. EPA Contract No. 68-W9-0057 Work Assignment No. 77-4RI24 Document Control No. 4400-77-AGBY JANU Y 1997 Mark . aylor, P.G. WESTON Work Assignment Manager WESTON Project Engineer William R. Doyle WESTON Region IV Pro Date: -1-1-/ l-'---1>+-'-/q__,_o/-__ 'f I Date: __ l_-_1..c.S_-..c.9_,_ ___ _ Approved by: ________________ _ Date: ________ _ Giezelle Bennett U.S. EPA Remedial Project Manager Approved by: ________________ _ Date: ________ _ Robert P. Stem U.S. EPA Regional Project Officer WESTON W.O. No. 04400-077-096-000I-O0 I NOR/K:\WP\04400\077\WPMAT001.WP 0 D D E I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Section 1 2 3 TABLE OF CONTENTS Draft RI/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January 1997 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... 1-1 SITE BACKGROUND AND PHYSICAL SETTING .... 2-1 2.1 2.2 2.3 2.4 Site Location ... . Site History .... . Site Characteristics .. 2-1 .. 2-1 .. 2-8 2.3.1 Physiography and Surface Drainage ............... 2-8 2.3.2 Regional Geology and Hydrogeology ............. 2-10 2.3.3 Local Geology . . . . . 2-11 2.3.4 Local Hydrogeology ....................... 2-12 References . . . . . . . . . . . . ... 2-13 CONCEPTUAL SITE MODEL . . . . . . . . . . . . . . . . . . . . . .... 3-1 . 3-1 . 3-1 3. I Overview . . 3.2 Study Areas . 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3.2.7 3.2.8 3.2.9 3.2.10 3.2.11 3.2.12 3.2.13 Fonner Wood Chip Processing Area ..... Fonner Rosin Warehouse North Tank Cradle Area Work Tank Area ........... . South Tank Cradle Area . Fonner Laboratory Area . Fonner Garage Area . . . Fonner Still Area ..... Former Transfonner Area . U-Shaped Settling Pond ......... . South Ponds Pond No. 3 Pond No. 4 . . . 3-3 . 3-5 . 3-6 . 3-6 . 3-7 . 3-7 . 3-7 . 3-8 . 3-8 . 3-9 .. 3-9 . 3-10 . 3-10 NOA/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 0 0 I I I I I I I I I I I I I I I This document was prepared by Roy F, Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January ~ 997 TABLE OF CONTENTS (Continued) Section Title 4 3.3 3.4 3.2.14 Drum Disposal Area ...... . 3.2.15 Former Refinery Building ... . 3.2.16 Above-Ground Piping System 3.2.17 Former Water Supply Wells 3.2.18 Sluice Area ..... . 3.2.19 Scrap Copper Area 3.2.20 Building Materials Initial Identification of Applicable or Relevant and Appropriate Requirements .... Scoping of Remedial Alternatives .......... . 3.4.1 Identification of Preliminary Remedial Response 3-10 3-11 3-11 3-12 ... 3-12 3-13 ... 3-13 . .. 3-13 ... 3-14 Objectives ............................. 3-17 3.4.2 Identification of Preliminary Remedial Response Actions and Remedial Alternatives .............. 3-18 RI WORK PLAN .................................. 4-1 4.1 4.2 4.3 4.4 Project Planning ..... Community Relations .. Subcontract Procurement Work Plan Approach Field Activities ............ . . 4-1 . 4-1 . 4-1 . 4-2 4.4.1 4.4.2 4.4.3 Site Preparation . . . . . . . . . . . . . . . . . . . . . . . 4-3 4.4.4 Well Survey . . . . . . . . . . . . . . . . . . . . . . . . . 4-4 Geoprobe® Groundwater and Soil Investigation ........ 4-4 4.4:3.1 Phase I Geoprobe® . 4 .4. 3. 2 Phase II Geoprobes® 4.4.3.3 Phase III Geoprobes® Surface Soil Investigation . 4-5 . 4-9 4-12 4-13 NOA/K: \ WP\ 04400\ 077\ WP MA TOO 1. WP 11 I 0 D E I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Section 4.5 4.6 4.7 4.4.5 4.4.6 4.4.7 4.4.8 4.4.9 4.4.10 4.4.11 Dratt RJ/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January 1997 TABLE OF CONTENTS (Continued) Sediment Sampling ........................ 4-16 Surface Water Sampling . . . . . . . . . . . . . . . . . . . . 4-16 Residential and/or Commercial Well Sampling ....... 4-18 Permanent Monitor Wells . . . . . . . . . . . . . . . . . 4-18 Aquifer Testing . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20 Former Water Supply Wells 4-21 Investigation Derived Waste .................. 4-21 Sample Analysis/Validation . 4-22 . 4-22 . 4-22 4.5.1 4.5.2 Sample Analysis Data Validation Environmental Fate and Transfer Modeling Evaluation ........ 4-23 Baseline Risk Assessment Development . . . . . . . . . . . . . . . . . 4-23 4.7.1 4.7.2 Human Health Risk Assessment 4.7.1.1 4.7.1.2 4.7.1.3 4.7.1.4 4.7.1.5 4.7.1.6 4.7.1.7 Data Collection and Evaluation .......... . Exposure Assessment and Documentation . . . . . Toxicity Assessment and Documentation . . . . . Risk Characterization . . Carcinogenic Risk . . . . . . . . . . . . . . . . . . . Noncarcinogenic Risk ...... . Risk-Based Remedial Options . . . Environmental/Ecological Risk Assessment 4. 7.2.1 Data Evaluation ... 4. 7.2.2 Exposure Assessment 4.7.2.3 Toxicity Assessment 4.7.2.4 Risk Characterization 4-24 4-25 4-26 4-27 4-28 4-29 4-29 4-30 4-30 4-31 4-31 4-33 4-34 NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 111 0 0 0 E E I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January 1997 TABLE OF CONTENTS (Continued) Section Title Page 5 6 7 8 4.8 RI Report . 4. 9 References . . 4-34 . 4-35 FEASIBILITY STUDY WORK PLAN ..................... 5-1 5.1 Development and Screening of Remedial Action Alternatives . . . 5-1 5.1.1 Identification and Screening of Remedial Technologies . 5-2 5 .1.2 Development of Alternatives ................... 5-2 5.1.3 Initial Screening of Alternatives ................. 5-3 5. I .4 Initial Screening Technical Memorandum ........... 5-5 5. 2 Task 5 -Detailed Evaluation of the Alternatives ............ 5-5 5.3 Feasibility Study Report .......................... 5-13 PROJECT MANAGEMENT . . . . . . . . . . . . . . . . . . . . ....... 6-1 6.1 Organization .. 6-1 6.1.1 6.1.2 6.1.3 6.1.4 6. 1.5 6.1.6 Work Assignment .......................... 6-1 Quality Assurance Coordinator . 6-I Project Field Team Manager . . 6-3 Field Safety Coordinator . . 6-3 Laboratory Staffing . 6-3 EPA Personnel . 6-4 6.2 Project Schedule ... 6. 3 Deliverables Schedule 6.4 Project Budget .... . 6-4 . 6-4 . 6-6 PROJECT MEETINGS .............................. 7-1 PROGRESS REPORTS . . . . . . . . . . . . . . . . . . .......... 8-1 NOR/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP IV n u 0 E I I I I I I I 1· I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Figure 2-1 2-2 2-3 3-1 3-2 4-1 4-2 4-3 4-4 4-5 6-1 6-2 Dratt RI/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January 1997 TABLE OF CONTENTS (Continued) LIST OF FIGURES Site Location Map Site Layout ..... Previous Sampling Locations for Law (1989) and NCDEHNR (1995) Investigations ................................ . Study Area Locations . Conceptual Site Model . . . . . . . . . . . . . . . . . . . . . . . . . . Phase I Geoprobe Investigation -Groundwater and Soil Sampling Page . 2-2 .2-3 . 2-7 . 3-2 . 3-4 Locations ................................. . . ... .4-6 Phase II Geoprobe Investigation -Groundwater and Soil Sampling Locations .................................. . Surface Soil Sampling Locations ......... . Surface Water and Sediment Sampling Locations Permanent Monitor Well Locations . . . . . . . . . . . . . . . . . . . . . . . . 4-10 4-14 Project Organization Project Schedule ................................ 4-17 4-19 . 6-2 . 6-5 ................................. NOA/K: \ WP\ 04400 \ 077\ WPMATOO 1, WP V n 0 0 I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. tt shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 2-1 2-2 3-1 3-2 5-1 Draft RI/FS Work Plan Reasor Chemical Company Site Section: Table of Contents Revision: 0 Date: January 1997 TABLE OF CONTENTS (Continued) LIST OF TABLES Title Page Summary of Analytical Results (Water Samples), NC DEHNR 1994 and Law Environmental 1989 . . . . . . . . . . . . . . . . . . . . . . . . ... 2-5 Summary of Analytical Results (Soil/Sediment), NC DEHNR 1994 and Law Environmental 1989 . . . . . . . . . . . . . . . . . . . . . . . . 2-6 Summary of ARAR Sources Evaluated 3-15 Preliminary Applicable or Relevant and Appropriate Requirements . . . . 3-16 Detailed Evaluation Criteria ............................. 5-8 NOA/I<;\ WP\ 04400\ 077\ WPMA TOO\ .WP VI B 0 0 I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. SECTION 1 INTRODUCTION Draft RI/FS Work Plan Reasor Chemical Company Site Section: 1 Revision: 0 Date: January 1997 Roy F. Weston, Inc., (WESTON@) is submitting this Remedial Investigation and Feasibility Study Work Plan to the U.S. Environmental Protection Agency (EPA), Region IV, for the Reasor Chemical Company site, located in Castle Hayne, New Hanover County, North Carolina. The Work Plan was prepared under Work Assignment No. 77-4RI24 of U.S. EPA Contract No. 68-W9-0057 in accordance with the Statement of Work provided to WESTON dated July 11, 1996. This Work Plan presents the objectives, overall scope and strategy, estimated budget and schedule for conducting Remedial Investigation/Feasibility Study (RI/FS) activities including a Baseline Risk Assessment for the Reasor Chemical Company site. The ultimate purpose of the RI/FS program is to provide and evaluate information to support EPA's selection of a remedial action alternative that will eliminate or sufficiently reduce the risk posed by the site to public health and the environment. The Reasor Chemical Company site RI/FS will be conducted in accordance with the requirements of the Statement of Work (SOW), National Contingency Plan (NCP) as amended by the Superfund Amendment and Reauthorization Act of 1986 (SARA), and "EPA Guidance for Conducting Remedial Investigation and Feasibility Studies Under CERCLA, Interim Final" (October 1988). NOR/K: \ WP\ 04400\ 077\ WPMATOO 1. WP 1-1 g 0 0 I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. SECTION 2 Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 SITE BACKGROUND AND PHYSICAL SETTING 2.1 SITE LOCATION The Reasor Chemical Company site is located in Castle Hayne, North Carolina, near Wilmington in the southeast portion of the state (Figure 2-1). The site consists of a vacant land parcel located 0.5 miles southeast of the intersection of NC Route 132 and US Route 117 (NC Route 133) (Figure 2-2). The geographic coordinates of the site are 34°20'36.5" N latitude and 77°53 '31" W longitude. To access the site from Raleigh, travel I-40 south, taking US 117 south near Castle Hayne. Bear left at the NC 132 interchange, approximately 1.0 mile south of the Northeast Cape Fear River. The entrance to the site is on the left (east) side of NC 132, 0.5 mile past the interchange. 2.2 SITE HISTORY The Reasor Chemical Company site is the fonner location of a stump rendering facility. Reasor Chemical operated the facility from 1959 to 1972, then sold the property to Martin Marietta Corporation, which in tum sold the site to the Cameron Company in 1986. The site has been inactive since 1972 and was dismantled at some time prior to 1986. Reasor Chemical produced turpentine, pine, resin, pitch, tall oil, pine oil, camphor, pine tar, and charcoal from pine tree stumps. The facility is believed to have used various solvents to extract raw product from chipped stumps, distilling the extract into separate product fractions. NOA/K:\ WP\ 04400\ 077\ WPMATOO 1 .WP 2-1 SITE LOCATION SITE LOCATION MAP REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA FIGURE 2-1 ------- ~ 0 N <{ I 0 0 v v 0 / r--r--0 / 0 0 v v 0 / <.:) 3: ,9- z ci z w _J 0- SOURCE: KUCERA NT, .&.ERl1'1... PHOTOS. REAi. PROPERTY MAP OF CAPE FEAR. LAW EM....,f!Ct.11.E:NTAL INC. SITE MAPS - - - - - l!!!!!!I l!!!!!!!I !!!!!! ~ == == WO OED AREA J pROPERTI' UNE 0 300' 600' SCALE FEET G:: i-----------R-E_A_S_O_R_C_H_E_M_I_C_A_L_C_O_M_P_A_N_Y __________ -,---------------,---,,R=□vc-:F~. ,....,~E""sr"'□""N,~]N'°C~. ------------! u l/) >-' _J (l_ CASTLE HAYNE. NORTH CAROLINA SITE LAYOUT FJGURE 2-2 DRA\JN WRS CHECKED ATE APPROVED ATE \/, □. NO. 04400-077 D\/G. NO. 04400-A2 0 0 0 E I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft Rl(FS Work Plan Reasor Chemical Company Site Section: 2 Revision: a Date: January 1997 The solvents used in the extraction process were apparently stored on site in 55-gallon dmms, remains of which are still visible in a surface dmm disposal area near the center of the property. Five surface impoundments or ponds, which apparently were used in the manufacturing process, are still present at the site. Spent stump chips were disposed on the ground surface in a "Sluice Area" in the northeast comer of the site. Concrete remnants of three aboveground storage tank arrays stand within the "Cradle Area" in the west-central portion of the site. Additionally, remnants of several building foundations remain on site including the main processing area located in the south central portion of the site. The remainder of the site presently consists of dirt roads and woodland. Reportedly, a fire occurred on a portion of the property in April 1972, damaging some of the on-site timber. In 1989, Law Environmental, Inc., (Law) completed an environmental site assessment of the property. Law collected soil, sediment, and groundwater samples. Benzene, toluene, and xylene (BTX) compounds were detected in the Cradle Area soil sample, in three of the four pond sediment samples, and in the groundwater sample. Acetone was detected in the Cradle, Sluice, and dmm disposal soils, and in three of the pond sediment samples. In 1995, a site inspection (SI) was conducted by the State of North Carolina -Superfund Section of the Department of Environment, Health and Natural Resources (NCDEHNR). The data and information obtained during the SI are summarized in Section 2.3 belo.w. Tables 2-1 and 2-2 summarize the data collected by Law and NCDEHNR. Figure 2-3 represents the locations of the samples collected during these previous investigations. Locations of private and public water supply wells sampled are not shown. NOR/K: \ WP\ 04400\ 077\ WPMATOO 1 .WP 2-4 --------------!!!!I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be disclosed, in whole or in part, without the express written permission of EPA. Sample# Law Sample #8 On-Site Table 2-1 Reasor Chemical Company Summary of Analytical Results (Water Samples) NC DEHNR 1994 and Law Enviornmental 1989 RC-001-PW RC-002-PW RC-003-PW PG 1 PG2 AP AC/Dickerson Davis Springer Prince George Ests. RC-004-SW P.G. Creek !!!!! == RI/FS Work Plan Reasor Chemical Company Site Section: Section 2 Revision: 0 Date: January 1997 RC-005-SW P.G. Creek Lowest == Location Monitorin~ Well Workplace Domestic Domestic Community (dwnstrm) (upstrm) Benchmark Medium: Date: 3/22/89 (1) Volatile Organic Comeounds (µg/l) Acetone ------ Benzene 3.6 --- Carbon disulfide NA --- Ethylbenzene NA --- Toluene 11 --- Xylenes (total) 18.9 --- Semi-Volatile Organic Come_ounds {pgll) Phenol 18 --- Pesticides ( µ gll) Toxaphene ------ ---= Indicates parameter not detected, or below quantitation limit. Tr= Indicates that trace concentration was reported. NA= Indicates that sample was not analyzed for parameter. Groundwater 11/2/94 (2) --- --- --- --- --- --- --- --- Surface Water Value (4) 6/1-7 /94 (3) 11/2/94 (2) ---NA NA ------3,500 ---------------1.2 ---NA NA ------3,500 ---------------700 --- ------------1,000 --------- ------10,000 ---NA NA ------21,000 ---------------0.032 (I) Samples collected by Law Environmental, Inc., during a Preliminary Environmental Liability Assessment of the neighboring Wilmington Auto Park Associates property. (2) Samples collected during the NC Superfund Section's Site Inspection. (3) Samples collected by the New Hanover County Engineering Department. (4) EPA 1994 (MCL/MCLG or Cancer Risk Screening Concentration for groundwater (Ref. 23). (5) See Appendix A, Ref. 8 for chemical laboratory analyses. NOR/K\WP\04400\077\TABLES.XLS Table 2-1 1/13197 Sample#: No. 1 No. 3 No. 6 Nos. 2,-4,5,7• Tnk.Crdl Sluict Drum Disp. 1'-illL Pond Location Am Am Arn Concentration Medium: Soil Date: 3/22/89 (!) Volatile Org_anic Comeounds ( JJ.K.!lsKl. Acetone 108 125 133 5,600 Benzene 5 --909 Ethylbenzene NA NA NA NA Methylene chloride 'NA NA NA NA Methyl ethyl ketone NA NA NA NA (2-butanone) Toluene 18 --90,000 Xylenes (total) 93 --25,000 Semi-Volatile Organic Comeounds (Jlgf}sg)_ Anthracene NA NA NA NA Benzo(k)fluornnthene NA NA NA NA Benzo(a) pyrene NA NA NA NA Chrysene NA NA NA NA Fluoranthene NA NA NA NA benzo(j,k)fluorene 2•methyl naphthalene NA NA NA NA Phenanthrene NA NA NA NA Phenol NA NA 5,120 175,000 P)Tene NA NA NA NA Pesticides (11g!gg}_ Toxaphene I -= Indicated parameter not detected, or below quantitation limit. NA· Indicates that sample was not analyzed for parameter. J = Indicates given concentration to be an estimated value. K = Indicates that actual concentration is less than value given. C = Indicates possible laboratory contamination. B = Indicates compound was also detected in laboratory blank. NOR/K.IWP\0-HOOI077\T"8LES.XLS ht:>lc 2-2 !!!!!! Table 2-2 Reasor Chemical Company Summary of Analytical Results (SoiVSediment) NC DEHNR 1994 and Law Emiornmental 1989 RC-004-SD RC-005-SD RC-006-SS RC-007-SD RC-008-SS P.G. Crttk P.G. Crttk Drum Dbp. On-s!tr l','WDitch Pond #1 Pond #2 (dwnstrm) (upstrrn) Arn (No.6) Ditch (bkgrnd) Sediment Soil Sediment Soil 28 J -- - -- 418 10 - -- - -- - -- -- -- -- 11/2/94 (2) LAW NC 2 JC -3 JC -- ------135 --- -3,288 ----21 18 2918 ------- -------23,458 --- -117,113 --333 K - -- --1,650 K -------1,650 K - ---800 -----2,083 - -- ---330 K ---- --667 ------------- -- --2,700 ----- * = Highest detected contaminant concentration in sediments from small Ponds # I & 2, from Drained Pond, and from Settling Pond. Drained pond not tested for phenol. Only Settling Pond was tested for toxaphene. (I) Samples collected by Law Env. during a Preliminary Environmental Liability Assessment of the neighboring Wilmington Auto Park Assc. property. (2) Samples collected during the NC Superfund Section's Site Inspection. (3) See Appendix A and Ref. 8 for chemical laboratory analyses. !!!!I !!!!!! == I RI/FS Work Plan Reasor Chemical Company Site Section: Section 2 Revision: O Date: January 1997 RC-009-SD Pond #J Pond #4 Srttling Pond (U-Shaprd) Sediment 3/22/89 3700 5600 117 41.7 909 - NA NA NA NA NA NA NA NA NA 5,550 10,500 ---11,200 - NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA 175,000 NA 903 NA NA - NA I NA - 1113/91 l:~------~--------;-----,--------------------------;:-------------i I I I I I I I •• I I I I RC-001-PW e I l 1 ' I ;~ I "' ' i a 1 j ~ ! ; t.., f 1 l I I I I , ; i f ! . i I i I ; I '-V w "' I I 'V 'V "' "' "' "' WOODED AREA 'V w SLUICE AREA ... ' t I I ~ \ "' •"' "' "' "' "' w 'V APPROXlt.lAlt: \ll'Ell.,UIO Ul,lllS 'V "' "' "' RC-004-SW • ~--3--w "' ,y "' -v RC-004-SD --v "' "' " "' "' "" 'V 'V "' 'V "' "' 'V 'V "' "' "' "' 'V "" ,y 'V "' REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA PREVIOUS SAMPLING LOCATIONS FOR LEGEND Rc-ooa-ss • NCDEHNR SAMPLING LOCATIONS Y LAW ENVIRONMENTAL SAMPLING LOCATIONS RC-002-PW • 0 300' SCALE 600' FEET LAW (1989) AND NCDEHNR (1995) DRA\JN \J,O,N□, I. 2 = PL T. sc. INVESTIGATIONS cHEcKrn--;-i'.':,si APPR□vrn oArE □"~4~~-0-077 L~~'.:w_'.'.,;:':"""""":''"::· :""'~r""_:"-:_'.':;:'g:.,'.rc:,".'."'.:_""'-:'."APS:'.._f'R<ll'ER __ !Y_"""_<F_CJF£._FDR_. _____________ _:F:_:l::::L::::E__:_:N~O:.:_· ______ L _______ .:_F.:,:1G:_U:_R:_:.=E__:2_-_:3:__ _______ _JL;· __ _,,J/=·.V...:.A./.:::::_ _ _1__..c7 -'-!.-1. ______ -1. ___ __,c...c0--'4--'4--'0--'0~--0~9~ I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 2.3 SITE CHARACTERISTICS Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1 !i)97 This section contains excerpts and references from the NCDEHNR Site Inspection Report dated March 1995. During the Work Plan process, WESTON contacted the appropriate agencies and resources relied upon for the site data. The following paragraphs were subsequently amended to incorporate any new or different information. 2.3.1 Physiography and Surface Drainage The Wilmington-Castle Hayne area lies within the Coastal Plain Physiographic Province (Ref. 8, p. 18). The geologic makeup of this province consists of a crystalline basement complex, overlain by a wedge of layered sedimentary bedrock strata, including Black Creek, the Pee Dee, and the Castle Hayne Formations. These sedimentary formations consist of sands, clays, and limestones dating from the Cretaceous and Tertiary Periods. The sedimentary wedge, which contains all the significant potable aquifers in the region, thickens toward the Atlantic coast, measuring 1,100 feet in Wilmington (Ref. 5, pp. 8-13). Overlying the sedimentary bedrock formations are unconsolidated sediments deposited during the Tertiary and Quaternary Periods (Ref. 5, pp. 8, 15, 18). Groundwater under unconfined conditions generally moves downward and laterally from recharge areas in the interstream areas to topographically lower discharge points at hillside springs and along streambeds, lakes, and the ocean (Ref. 8, pp. 6, 14, 24). Based on surface topography and surface drainage, groundwater beneath the site is anticipated to flow in a general south-southeasterly direction, toward Prince George Creek and the surrounding swamps (Ref. I). · NOA/K:\WP\04400\077\WPMATOOl.WP 2-8 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 Based on the site's topography (Ref. I), surface drainage at the site is toward the southeast, in the direction of Prince George Creek. A system of drainage ditches runs parallel to the unpaved perimeter and interior roads at the site. These ditches receive overflow from the settling pond, the two impoundments south of the chip staging area, the sluice area, and other source areas at the site (Ref. 3, pp. I, 3; Ref. 4, Fig. 2). One ditch flows across the center of the site, while the other two skirt its south and east edges. The three intermittent channels begin to converge southeast of the site, but do not intersect, terminating instead at three probable points of entry (PPEs) spaced a few hundred feet apart along the north edge of wetland areas which border the creek (Ref. 3, pp. 6, 10; Figs. 2-3). Prince George Creek flows westward, passing within approximately 700 feet of the site, then continuing toward the Northeast Cape Fear River. The Prince George Creek is reported to be tidally influenced downstream of U.S. Route 117, approximately I mile downstream from the site, but the creek does not experience flow reversal upstream of this location (Ref. 9). For 0.6 miles both upstream and downstream of the site, the creek meanders slowly through a cypress swamp (Ref. I; Ref. 7, pp. 6, 9). Source areas at the site are not located within mapped flood plains (Ref. 28). Based on published drainage area measurements and mean annual runoff statistics, the mean annual flow along the non-tidal segment of Prince George Creek is calculated to be 13.6 cubic feet per second (cfs). The remainder of the creek has a calculated mean annual flow of 20.2 cfs (Ref. 10). The water in the entire Creek is designated as Class "C Sw." Class C indicates waters suitable for aquatic life propagation and survival, fishing, wildlife, secondary recreation, and agriculture. Sw indicates swamp water, with low velocity and other natural characteristics differing from adjacent streams (Ref. 11). NOR/K: \ WP\ 04400\ 077\ WP MA TOO 1. WP 2-9 I I I I I I I I I I I I I I I I I I. I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: O Date: January 1997 Prince George Creek enters the Northeast Cape Fear River 5.5 miles downstream from the most downstream PPE. The mean annual discharge of the river downstream of Prince George Creek is approximately 2,370 cfs (Ref. 10). The Northeast Cape Fear River, however, undergoes tidal reversal (and salt water intrusion) along its main channel as far as 6.5 miles upstream of the mouth of Prince George Creek (Ref. 13, pp. 19, 31-35, Plate I). Flow reversal also occurs along the river's tributaries, such as Cowpen Branch, Long Creek, Morgan's Creek, and Turkey Creek (Ref. 1; Ref. 9; Ref. 10). For this reason, the surface water pathway divides at the mouth of Prince George Creek, continuing 9.5 miles downstream and 6.5 miles upstream along the main Cape Fear River channel. Tidally influenced portions of its tributaries within 15 water miles from the site are also within the pathway (Ref. 10; Figs. I, 3). Upstream of Prince George Creek, the Northeast Cape Fear River is designated as Class "B Sw," indicating swamp water, suitable for primary recreation and any other use specified for Class C waters. Downstream of the creek, the river is designated Class "C Sw" (Ref. 11). 2.3.2 Regional Geology and Hydrogeology Potable bedrock aquifers beneath the site include the Cretaceous Pee Dee Formation and the overlying Eocene Castle Hayne Formation. The Pee Dee Formation consists of silt, clay, and water-bearing sands with some impure limestone beds (Ref. 5, pp. 9, 13, 63). The Castle Hayne Fonnation consists of shell, marl, sand, and limestone (Ref. 5, p. 13). Potable water production from the Pee Dee aquifer is limited to the uppem1ost of 4 separate water-bearing sandy layers within the formation. A confining clay layer which normally caps the sand unit is absent beneath the site and in areas to the north and west (Ref. 5, pp. 9, 10, 14). The two formations therefore behave as a single aquifer. NOA/K: \ WP\ 04400\077\ WP MA TOO 1. WP 2-10 I I I I I I I I: I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 The City of Wilmington's drinking water source consists of a surface water intake located outside of the study area on the Cape Fear River. No municipal water supply wells or distribution lines are located within 4 miles of the site. The entire population within 4 miles of the site is supplied water from domestic or community wells (Refs. 6-7). The 1994 community well database indicates that 19 community wells supply approximately 4,238 residents within a 4-mile radius of the site (Ref. 7). The nearest community well, supplying 50 people, is located in a mobile home park 1,500 to 2,500 feet southwest of the site. Another community well, supplying 600 people, is located 3,000 feet southeast of the site in a housing subdivision (Ref. 7; Fig. 1). 2.3.3 Local Geology Little information is available regarding the overburden geology of the site. In general, however, the bedrock formations in this part of the county are overlain by unconsolidated sandy beach, dune, and stream channel deposits, which vary considerably in thickness (Ref. 5, pp. I 8- 20). Because of the lack of confining clay layers, the Castle Hayne and Pee Dee aquifer is anticipated to function as a water table aquifer at the site. Historical well records do not indicate that the overburden sands were commonly used as a water-supply aquifer within a mile of the site (Ref. 5, pp. 20, 62-63, 67, 71, Fig. 3). Portions of the site are underlain by five different natural soil types. The eastern third of the site is mapped as Wrightsboro fine sandy loam (0-2 % slope). The western third is mapped as Leon sand. The south-central portion of the site is mapped as Seagate fine sand, and the north central portion of the property is mapped as Lynchburg fine sandy loam and Onslow loamy fine sand (Ref. 12, pp. 8-10, 12, 14, Sheet No. 3). NOA/K:\ WP\ 04400\ 077\ WP MA TOO\ .WP 2-11 I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 Surficial soils at the site typically consist of 3 to 8 inches of dark gray to light gray fine sand I or fine sandy loam. At most on-site locations, the surface layer is underlain by layers of sand, sandy clay loam or clay loam to a depth of approximately 65 inches. The subsurface soils are I expected to be sandier in the southern and western portions of the site, but sandy clay loam is I I I· I I I I I I I more prevalent in the mapped subsoils corresponding to contaminant source locations (Ref. 4, Fig. 2; Ref. 12, pp. 60-62, Plate 3). 2.3.4 Local Hydrogeology Historical well records reveal that four production wells were once drilled at the site for Reasor Chemical Company. At least one of the wells was never used. Records indicate that the wells were cased to depths ranging from 14 to 34 feet below surface, which may approximate the respective bedrock depths at each well location (Ref. 5, p. 63). The wells penetrated both the Castle Hayne and Pee Dee Formations, to a maximum depth of 212 feet. Records indicate that several other wells in this part of New Hanover County also penetrated both bedrock formations (Ref. 5, pp. 62-63, 67, 71, Fig. 3). Only 1 production well, non-operational, was identified during site visits (Ref. 6). The NC Division of Environmental Management installed one monitoring well at the site and four others on adjacent land to the east, in order to monitor groundwater elevations during Martin Marietta's use of the adjacent property (Ref. 4, p. 5). The DEM monitoring well at the site is reportedly cased to 22 feet, and screened in limestone from 22 to 48 feet deep (Ref. 30). The Castle Hayne Formation's thickness at the site is generally estimated at slightly over 20 feet (Ref. 5, p. 16). NOR/K: \ WP\ 04400\ 077\ WPMATOO 1. WP 2-12 I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RIJFS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 2.4 REFERENCES 2. 3. 4. 5. 6. 7. 8. 9. 10. United States Geological Survey 7.5 Minute Orthophotomap Quadrangles: Castle Hayne, NC, 1970; Scott's Hill, NC, 1970; Rocky Point, NC, 1970; Mooretown, NC, 1970; 7- 1/2 Minute Topographic Quadrangle: Currie, NC, 1980; 1 :24,000. Nicholson, Bruce, NC Superfund Section, Preliminary Assessment Reconnaissance, Reasor Chemical, Castle Hayne, North Carolina, July 23, 1991. Parker, Stuart F., NC Superfund Section, Reasor Chemical SI Reconnaissance and Sampling Report, November 4, 1994; Attached Field Notes, August 2, 1994, November 2, 1994. Law Environmental, Inc., Preliminary Environmental Liability Assessment, Prepared for Wilmington Auto Park Associates, April 1989. Bain, George L., Geology and Ground-water Resources of New Hanover County, North Carolina, US Geological Survey Groundwater Bulletin Number 17, 1970. Parker, Stuart F., NC Superfund Section, Memorandum to File: Municipal Drinking Water Supplies within the Study Area, July 25, 1994. Moore, Martha, NC DEHNR, Division of Environmental Health, Public Water Supply Database, July 28, 1994. Heath, R.C., US Geological Survey, Basic Elements of Groundwater Hydrology with Reference to Conditions in North Carolina, Open-file Report 80-44, Raleigh, NC, 1980. Nicholson, Bruce, NC Superfund Section, Memorandum to File: Telecons with Ed Beck, Water Quality Section, and Rick Shriver, Groundwater Section, Wilmington Regional Office, NC Division of Environmental Management, August 29, 1991. Parker, Stuart F., NC Superfund Section, Memorandum to File: Surface Water Pathway Definition, July 20, 1994. NOA/K: \ WP\ 04400\ 077\ WPMAT00 1. WP 2-13 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 11. 12. 13. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 2 Revision: 0 Date: January 1997 NC DEHNR Division of Environmental Management, Classifications and Water Quality Standards Assigned to the Waters of the Cape Fear River Basin, !SA NCAC 2B .0311, Current through Febmary 1, 1993. US Department of Agriculture, Soil Conservation Service, Soil Survey of New Hanover County, North Carolina, April 1977. Giese, G. L.; Wilder, H. B.; Parker, G. G., Jr., Hydrology of Major Estuaries and .Sounds of North Carolina, US Geological Survey Water Supply Paper 2221, 1985. NQR/K:\ WP\04400\ 077\ WPMATOO 1 . WP 2-14 I I I I I I I I. I I I I This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.1 OVERVIEW SECTION 3 CONCEPTUAL SITE MODEL Draft Al/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 Section 3 presents the initial conceptual site model including an evaluation of the study areas, preliminary identification of applicable or relevant and appropriate requirements (ARARs), and scoping of remedial alternatives. 3.2 STUDY AREAS This subsection presents an initial evaluation of the potential source areas identified on the Reasor Chemical Site as a result of WESTON's review of the available background information. In addition to discussing the physical features and locations of the source areas, the release mechanisms, pathways, and potential impacts to the environment are also presented. Figure 3-1 depicts each of the study areas discussed in this section. During previous site investigations, some level of contamination has been documented in soil surface water and sediment at several of the potential contaminant source areas (e.g., surface impoundments, sluice area, etc.). Additionally, obvious contamination has been observed in some areas such as the drum disposal area and beneath the tank cradles. However, for other areas on the site (e.g., former _laboratory, garage, and pipe shop), no samples have been collected but the nature of activities at these areas indicates that chemicals were likely handled and/or stored, creating a reasonable potential for release. NOR/K:\ WP\04400\077\ WPMA T001.WP 3-1 I,--------------'=--------------------- I I I I I I I I I I I I I I I SOURC£: OLD R AIL LIN[ ACC[ss ROAo KUC£RA INT. AERIA.l PHOTOS. REAL PROPERTY M OF CAPE f'EAR. LAW EN"IRONMENT"1. INC. sm: MAPS 2: .::J ;::::: ::, I DRUM DISPOSAL AREA NORll< TANK CRADLE AREA LABOR.i.TORY pROPER1Y UNE PLT. SC. FILE NO. WOODED AREA --- -'PPROXIMA TE WETI..ANO UUITS REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA STUDY AREA LOCATIONS FIGURE 3-1 SLUICE AREA DRA\JN WRS CHECKE?J',(J ' I 'iv 0 SCALE DATE 12-96 DATfi ,?.'l l/12 ,, 200· 400' FEET APPROVED DATE \I. □. NO. 04400-077 DIJG. NO. 04400-08 I I I I I I I I ' I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shalt not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RlfFS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 The primary suspected release mechanisms identified are potential spillage or other release of chemicals either directly onto the ground surface and/or through preferential pathways such as cracks or openings in building floors or concrete pads; storage of waste in ponds/lagoons; on-site plumbing; septic tanks; or wells. Such releases could affect surface and subsurface soils, surface water, sediment, and groundwater. Given the sandy nature of surface soils and shallow (i.e., approximately 5 feet) water table, it is very likely that on-site releases would impact surficial groundwater. During the site visit no obvious odors were noted around the potential source areas and review of background information indicates that there is no history of complaints or concerns related to on-site air quality. Given the nature of the chemicals used on-site, the humid climate in which the site is located, and the absence of any obvious odors on-site, WESTON does not believe that airborne contamination is a significant area of concern for the Reasor Chemical Site. Figure 3-2 depicts a graphical representation of the conceptual site model based on the background inforn1ation collected to date. 3.2.1 Former Wood Chip Processing Area The wood chip processing area is located in the southeastern portion of the site and consisted of a process line trending southwest to northeast (see Figure 3-1). This area currently consists of a long concrete pad with rem!Jants of buildings at each end. Based on review of historical information, the extraction process began with the grinding of pine stumps into chips at the Millhouse and subsequent storage of the ground stumps in the Chip Bin. The chips were taken to the Extractor Building and solvents were used to remove the resin from the chips. The resin NOR /K:\ WP\ 04400\ 077\ WPMATOO 1. WP 3-3 - - PRIMARY SOURCE DRUMS PROCESS BUILDINGS LAGOONS -PallfiY--RELEASE MECHANISM SPILLS/ LEAK.AGE ·--SECONDARY SOURCE INFILTRATION/ 1--~><r PERCOLATION SOIL .• S...,DA- RELEASE MECHANISM SOIL -PATHWAY - EXPOSURE ROUTE - INGESTION --- RECEPTOR 0 0 0 DERMAL CONTACT I O I O I LI _ .. __L _ _J INGESTION INFTLTRATION/ n..ru ,1 r Pr]OW ~ PERCOLATION I-~ GROUND WATER1-----~ nm,,,.,.,, DERMAL CONTACT 0 • 0 I G 11 f---_ _L__...J 8 INGESTION ~ e o 11 • 0 OVERTOPPING '---~ '---~ DIKE STORM WATER RUNOFF SURFACE WATER AND SEDIMENTS I----INHALATION I O I 9 11 ° • I SLUICE AREA SCRAP COPPER AREA LEAKAGE CONCEPTUAL SITE MODEL REASOR CHEMICAL CASTLE HAYNE, NORTH CAROLINA FIGURE 3-2 DERMAL CONTACT I O I O 11 " I 0 I I I I I I I I I I' I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft Rl(FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 material was then further processed at other locations in the plant. The spent wood chips were stored in the Fuel Bin and used to fire the boilers located at the northeast end of the process line. The most likely areas of potential contamination is the fom1er Extractor Building location and the former storage tank area. However, given the length of time since operations ended and the lack of detailed information on house keeping practices, the potential for residual solvents and/or pine tar to be spread along the whole area cannot be ruled out. Thus, the wood chip processing area will be investigated as a single source area. Releases could impact surface soil, subsurface soil, and groundwater. Surface water and sediment could also be affected by runoff from this area. 3.2.2 Former Rosin Warehouse Based on historical information, the Rosin Warehouse was located in the northwestern portion of the site immediately south of Tank Cradle Area 1 (see Figure 3-1). This one-story, steel frame and metal sided structure was approximately 40 ft by 40 ft, and was presumably used to store extracted rosin. Environmental concerns in this area are related to the potential release of chemicals from past storage activities at this former building site. Potential release of solvents/pine products could have impacted soil and groundwater. NOA/I<:\ WP\ 04400\ 077\ WPMATOO 1 .WP 3-5 I I I I I .. - I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.2.3 North Tank Cradle Area Draft RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 The North Tank Cradle Area is located in the northwestern portion of the site. This area currently consists of a concrete pad remnants of several tank cradles. Tar is visible on the concrete pad beneath the former tank cradles. Analytical results from a soil sample collected in this area by Law indicated the presence of acetone, benzene, toluene, and xylene. The subject sample was analyzed for volatile organic compounds only. The tar coating on the concrete indicates releases have occurred in this area. Surface and subsurface soil as well as groundwater may have been impacted from releases associated with the tanks forn1erly located in this area. 3.2.4 Work Tank Area The fonner Work Tank area is located in the central portion of the site immediately south of the Drained Pond and west of the former still building (see Figure 3-1). This area currently consists of several tank cradles situated on a concrete pad. The tanks were presumably associated with the adjacent distillation process. To date no samples have been collected in this area. Surface and subsurface soil, surface water/sediment as well as groundwater may have been impacted from releases associated with the handling and storage of chemicals in the Work Tank Area. Releases pathways include _direct spillage onto the ground, seepage through cracks in the concrete pad situated beneath the tanks, and/or through piping associated with the work tanks. NOA/K:\ WP\ 04400\ 077\ WPMAT001.WP 3-6 I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.2.5 South Tank Cradle Area Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 The South Tank Cradle Area is located in the central portion of the site immediately northeast of the chip processing area (see Figure 3-1). This area currently consists of several tank cradles situated on a concrete pad. To date no samples have been collected in this area. 3.2.6 Former Laboratory Area The laboratory building was located in the west central portion of the site south of the fonner Rosin Warehouse (see Figure 3-1). The laboratory building was reportedly a one story wood frame structure with both plumbing and electricity. Potential releases to soils and groundwater related to use/storage of chemicals associated with the laboratory is the primary concern in this area. Potential release pathways include through cracks in the floor, from the building plumbing and septic system or direct discharge onto the ground. 3.2.7 Former Garage Area The former garage area is located in the southwestern portion of the site. This high one story steel framed and metal clad structure was approximately 40 ft x 50 ft in size and had roll curtain steel doors. It reportedly had electricity but no plumbing. The garage was presumably used to store and maintain facility vehicles. Review of appraisal records for the site indicates that there were several vehicles including a station wagon, two pickup trucks, four dump trncks, three cranes, a bulldozer, tractor, fire truck, and a front end loader. NOR/K:\ WP\ 04400\ 077\ WPMAT00 1. WP 3-7 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 Potential releases to soil and groundwater from petroleum associated with operation and maintenance of vehicles associated with the fom1er Reasor Chemical site is the primary concern in this area. 3.2.8 Former Still Area The former still area is located in the central portion of the site immediately south of the Drained Pond. It presumably housed the plant distillation unit. The subject building was reportedly a two story, steel framed and metal clad structure approximately 16 ft by 25 ft in size and had electricity but no heating, air conditioning nor plumbing. The primary potential release pathway for the Former Still Area is seepage through cracks in the building floor. 3.2.9 Former Transformer Area Historical information indicates that transformers were previously located northwest of the chip processing area. Remnants of the concrete pad that contained the transformers is currently present on-site. During the operational period of the Reasor Chemical facility (1959-1972), dielectric fluids used in transfonners sometimes contained polychlorinated biphenyls (PCBs). Potential release of PCB containing fluids into the surrounding soil a.nd groundwater from operation and maintenance of the_ transformers is the primary concern in this area. NOR/ K: \ WP\ 04400\ 077\ WPMATOO 1. WP 3-8 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.2.10 U-Shaped Settling Pond Dratt RlfFS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 AU-shaped Pond is located in the northeastern portion of the facility. Reportedly this pond was used as a reservoir for water storage. However, analytical results from a sample collected by Law in 1989 in the southeastern portion of the pond indicated the presence of acetone and phenol in sediment. The primary concern in this area is release of chemicals into the surface water, sediment, and groundwater as the result of past discharges from plant operations into this pond. 3.2.11 South Ponds South Pond No. 1 covers an area of approximately 0.2 acres. Two sediment samples collected from this pond also revealed the presence of benzene, toluene, xylene, acetone, and phenol. The South Ponds are located in the southeastern portion of the site. South Pond No. 2 (i.e., the smaller of the two ponds) covers an area of approximately 0.1 acres. Analytical results from a sediment sample collected by NC DEHNR during the SI indicated the presence of benzene, ethylbenzene, toluene, and xylene. Environmental concerns related to the South Ponds are from potential release to surface water/sediment and groundwater from chemicals previously discharged into the pond from past plant operations. NOR/K: \ WP\ 04400\ 077\ WPMATOO 1 .WP 3-9 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.2.12 Pond No. 3 Draft RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 Pond No. 3 is located in the central portion of the site. This pond was apparently used as a waste lagoon in conjunction with Pond. No. 4. Sediment samples collected by Law revealed the presence of benzene, toluene, xylene, acetone, and phenol. 3.2.13 Pond No. 4 Pond No. 4 is located in the north central portion of the site and consists a square shaped depression covering an area of approximately 0.1 acre. The pond bottom appeared to be 2-4 feet below the surrounding land surface and staining of the soil was evident. This forn1er pond was apparently previously used as a waste lagoon. Results from a soil sample collected from this area by Law indicated the presence of acetone, benzene, toluene, and xylene. Environmental concerns related to Pond No. 4 are from potential release to soil and groundwater from chemicals previously discharged into the pond from past plant operations. 3.2.14 Drum Disposal Area The Drum Disposal Area is located on the east side of an on-site drainage ditch in the north central portion of the site (Figure 3-1). This area consists of approximately 20-30 badly rusted, overturned 55-gallon drums scattered along a 50-75 feet stretch of drainage ditch. Some of the drums contain a dark brown resinous material believed to be associated with past plant operations. No evidence of surface contamination was observed during the site visit; however, the ground was covered with pine needles and other vegetation, preventing complete observation NOA/K;\ WP\04400\077\ WPMAT001.WP 3-10 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, 1nc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 of surface soils. A soil sample from this area indicated the presence of acetone, phenol, and PAHs. Leakage and leachate from the overturned and rusted drums in this area are the primary release mechanism. The leakage could impact surface soil, subsurface soil and groundwater. Given the drums position adjacent to a drainage ditch, leakage could also impact surface water and sediment. 3.2.15 Former Refinery Building The fom1er refinery building was located in the central portion of the site immediately northwest of the fonner extractor (see Figure 3-1). This building occupied an area of approximately 4,600 square feet and had a concrete floor. Appraisal records indicate the presence of up to nine steel tanks associated with this building. Presumably the pine tar compounds were conveyed to this building for refinement following the extraction process. Release of chemicals through cracks in the floor into the underlying soil and groundwater is the primary concern related to the Former Refinery Building. 3.2.16 Above-Ground Piping System During the EPA-WESTON site visit, remnants of an above-ground piping system was observed. Reportedly this system was used to transport pine products across the site during past operations. Leakage from past operation of the above-ground piping system could impact surface and subsurface soils as well as groundwater and surface water/sediment. NOA/ K: \ WP\ 04400\ 077\ WPMATOO t. WP 3-11 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 3.2.17 Former Water Supply Wells Draft RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 Historical infomrntion indicates up to 4 wells were drilled at the Reasor Chemical Site and at least one of the wells was never used. Records indicate that wells were cased from 14-34 feet below land surface, possibly indicating the depth to bedrock. To date, only one of these wells has been found and it is reportedly located near the Work Tank Area. The wells apparently penetrated the Castle Hayne and Pee Dee Formations to a maximum depth of 212 feet. Additionally, the NC Division of Environmental Management installed a monitoring well in the southeast comer of the site to monitor groundwater elevations because of Martin Marietta's operation of a nearby quarry. The subject well was reportedly screened in limestone fom1 22-48 feet. During The NC DEHNR site investigation and WESTON' s site visit, this well could not be located and may have been dismantled or damaged. Degradation of or damage to the casings and/or covers of these wells could provide a preferential pathway into the groundwater, resulting in a release of suspected site contaminants into the aquifer. 3.2.18 Sluice Area The Sluice Area is located in the northeastern portion of the site and consists of wood chips scattered on the ground. In some areas the wood chips are several inches deep. The Sluice Area covers an area of approximately 2 acres. A soil sample collected from this area by Law in 1989 and analyzed for acetone and benzene contained an acetone concentration of 125 µ,g/L. The I sample was not analyzed for other VOC constituents, PAHs, pesticides, or metals. I NOR/K; \ WP\ 04400\ 077\ WPMAT001. WP 3-12 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., .expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 The primary concern in this area is leaching of any residual chemicals in the wood chips (i.e. solvents and pine tar) into the soil and groundwater. Additionally nmoff from this area could also impact surface water and sediment. 3.2.19 Scrap Copper Area An area containing charred scrap wire insulation and conduit is located in the west-central portion of the site. Apparently electrical wiring from the site was burned in this area to recover the copper from the insulation. Burning of the material may have resulted in release of copper and/or chemicals associated with the insulation onto the surface soil. These materials (if present) could migrate to subsurface soils and groundwater. 3.2.20 Building Materials Asbestos materials were reportedly used in the construction of some of the site buildings. Although no evidence of these materials is present on the surface, WESTON will note any suspected materials found during the R1 soil sampling activities. 3.3 INITIAL IDENTIFICATION OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS Superfund remedial actions under SARA must attain the applicable or relevant and appropriate requirements (ARARs) of federal, state, or local environmental statutes, whichever are most stringent. Federal standards could include RCRA, Clean Air Act, Safe Drinking Water Act, Clean Water Act, or the Toxic Substances Control Act. State of North Carolina standards could NOR/ K:\ WP\ 04400\ 077\ WPMATOO 1. WP 3-13 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Dratt RlfFS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 include any promulgated by the State Environment Management Commission. Screening of the remedial action alternatives will require an evaluation of each alternative with regard to its ability to comply with the ARARs. The ARARs are generally based on acceptable levels of contamination for the preservation of the environment and the public health and welfare. ARARs may also include consideration of technical and economic feasibility. ARARs can be categorized as: (I) chemical-specific, (2) location-specific, or (3) action-specific requirements. Chemical-specific requirements are used to define acceptable exposure levels and are used to define remedial action objectives. Location-specific requirements set restrictions on activities within specific locations, such as floodplains or wetlands. Action-specific requirements set restrictions for particular treatment and disposal activities pertaining to hazardous wastes. ARARs will be considered throughout the RI/FS process. As the Rl/FS progresses, each ARAR will be defined based on the accumulated site data. Preliminary sources of ARARs have been identified for the Reasor site and are included in Table 3-1. A preliminary list of chemical-specific ARARs for the previously identified contaminants are presented in Table 3-2. 3.4 SCOPING OF REMEDIAL ALTERNATIVES Based on the existing site info_rmation collected during the State of North Carolina Site Inspection and a conceptual understanding of the site conditions, potential remedial action alternatives have been identified for each contaminated medium. This preliminary list of NOA/K:\ WP\04400\077\ WPMAT001.WP 3-14 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA FEDERAL STATE Table 3-1 Summary of ARAR Sources Evaluated Resource Conservation and Recovery Act (RCRA) Clean Water Act (CW A) Safe Drinking Water Act (SDW A) Clean Air Act (CAA) Occupational Safety and Health Act (OSHA) Hazardous Materials Transportation Act Protection of Wetlands (Executive Order I 1990) Floodplain Management (Executive Order 1 1988) Draft RljFS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 Regulations Protecting Landmarks, Historical, and Archeological Sites Endangered Species Act Fish and Wildlife Coordination Act EPA OSWER Soil Screening levels North Carolina Hazardous Waste Management Rules and Solid Waste Management Law North Carolina Water and Air Resources Act North Carolina Water Pollution Control Regulations North Carolina Drinking Water Act North Carolina Drinking Water and Groundwater Standards North Carolina Surface Water Quality Standards North Carolina Air Pollution Control Regulations NOA/ K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 3-15 12/98 -- - ------- --- --- - - This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Table 3-2 Dratt Rl(FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 Preliminary Applicable or Relevant and Appropriate Requirements Surface Water Drinking Aquatic Fish/Water Compound Groundwater' Water' Life Ingestion Acetone 700 NIA NIA NIA Toluene 1,000 1,000 11.0' 6,800' Xylenes 530 10,000 NIA NIA Phenol 300 NIA NIA 21,000' Toxaphene 0.031 1,000 0.0002' 0.00073' Benzene 1.0 5 NIA 1.2' 1 All units are micrograms per liter (µg/L). 2 State of North Carolina Groundwater Quality Standard; 15NCAC2L.0202. 3 Drinking Water Regulations and Health Advisories; US EPA Office of Water, November 1994. 'State of North Carolina Surface Water Standards; 15NCAC2B.0208-.021 I. 'Water Quality Standards; Federal Register Vol. 57.12/22/92, U.S. Environmental Protection Agency. 'Draft Interim Soil Screening Level Guidance (Oswer, August 19, 1993). 7 N/ A -no criteria or standard available. NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1 .WP 3-16 Human Health/ Fish Soils' Consumption (mg/kg) NIA NIA NIA 16,000.0 NIA 160,000.0 4,600, 0005 NIA 0.00075' NIA 71.44 22.0 12/96 - I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 alternatives is a general classification -of potential actions developed to help ensure that the necessary data is collected during the RI to adequately analyze each alternative. 3.4.1 Identification of Preliminary Remedial Response Objectives Based on the study areas described in Subsection 3.2, the following media and related remedial action objectives have been developed: On-Site Soil -Surficial soils have been found to contain benzene, toluene, xylene, acetone, and phenol. The objective related to protection of human health would be to prevent ingestion and/or direct contact with soil having 104 to 10·• excess cancer risks on above reference doses. The remedial action objective for environmental protection would involve prevention of contaminant migration into the groundwater. Surface Water and Sediments -Sediments and surface water from the on-site surface impoundments, as well as sediment from the wetland areas leading to Prince Georges Creek, also revealed low levels of volatile organic compounds. The protection of human health to prevent ingestion and/or direct contact is the primary objective. The remedial action objective for the protection of the environment would involve protection of endangered animal or plant species and protection of fisheries downstream of the site. Groundwater -To date, benzene, toluene, xylene, and phenol have been detected in the groundwater in on-site wells adjacent to the surface water impoundments. No off-site organic contaminants have been detected in the closest public drinking wells. The remedial action NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 3-17 I I I I I I I I I I I I I I I I I I ·I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: 0 Date: January 1997 objective will be to confinn the limits of the contamination plume and restore the aquifer to acceptable cleanup levels. Solid Waste Materials -Solidified pine tar materials are present in drums and on the surface adjacent to the tank cradle areas. While no chemical analysis has been performed on the material itself, soil samples collected nearby reveal the presence of BTX, acetone, and phenol. The remedial action objectives for this solid waste material are the same as for on-site soils - prevent ingestion and direct contact with wastes having 104 to 10-6 excess cancer risks and prevent migration of contaminants into groundwater. 3.4.2 Identification of Preliminary Remedial Response Actions and Remedial Alternatives A preliminary evaluation of potential response actions and remedial alternatives have been conducted. The following lists are for each medium includes alternatives that are relevant to the site conditions and are based on the amount of information known to this point. This general list will be refined as data from the RI is made available. Soil • • • No action/institutional controls such as fencing and deed restrictions . Containment actions -Capping with an impermeable soil or synthetic layer . Surface controls to divert surface water. Excavation and off-site disposal at a permitted facility . NOR/ K:\ WP\ 04400\ 077\ WP MA TOO 1 . WP 3-18 I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc,, expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • Sediments • • • Groundwater • • • • Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 3 Revision: O Date: January 1997 In-situ treatment using a soil vapor extraction technology to remove VOCs from the unsaturated soils. No action -Natural degradation within wetland areas . Excavation and off-site disposal at a permitted facility . Excavation and on-site biological treatment. No action/institutional controls -Alternative residential water supply and monitoring. Containment action -Capping with an impermeable barrier to reduce stom1water infiltration. Collection and treatment on-site followed by reinjection of surface discharge . In-situ treatment using an air sparging technology in conjunction with soil vapor extraction. Solid Waste Materials • • No action/institutional controls including fencing . Drums and solids removal with off-site disposal. NOA/K: \ WP\ 04400\ 077\ WPMAT00 1. WP 3-19 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 4.1 PROJECT PLANNING SECTION 4 RI WORK PLAN Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date; January 1997 This section of the RI/FS Work Plan includes a comprehensive description of the work to be perfom1ed that will fully characterize the site conditions. A complete description of the planned methodologies to investigate each media is discussed along with the rationale for the selection of each methodology. This section also includes the approach for conducting a Baseline Risk Assessment based on data collected during the RI. 4.2 COMMUNITY RELATIONS The community relations program for the Reasor Site will be carried out by EPA. However, WESTON will be available to assist EPA as needed. WESTON's primary area of community relations support will be attendance at public meetings to assist EPA in presenting technical information. 4.3 SUBCONTRACT PROCUREMENT To meet the RI/FS requirements for the Reasor site, several subcontractors will be used as appropriate to conduct various field services. These services include a direct-push technology (DPT) geologic and groundwater investigation, drilling and monitoring well installation, and surveying of the installed monitoring wells. The subcontractor services will include: NOA/K:\ WP\04400\077\ WPMAT001.WP 4-1 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • • • • Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 Providing equipment and manpower for soil and groundwater sampling using DPT (Geoprobe®); Providing equipment, manpower, and materials for drilling, soil sampling, and monitor well installation; Analytical characterization of investigative derived wastes, geochemical and geotechnical testing; Land surveying for vertical and horizontal coordinates of monitoring wells and other physical features. Request-for-quotation packages will be prepared and issued to at least three finns qualified to provide each required service. Copies of the packages will be provided to EPA. Quotations and qualifications of the firms will be reviewed, subcontractors will be selected, and subcontracts will be executed. Copies of the subcontracts will be provided to EPA. 4.4 WORK PLAN FIELD ACTMTIES The following paragraphs discuss the activities to be conducted during the field investigation at the former Reasor Chemical site (the site) in Castle Hayne, North Carolina. Activities to be conducted by WESTON at the site include groundwater, soil, surface water, sediment, and residential and/or commercial well sampling. WESTON will also attempt to sample any remaining drums or tanks for characterization purposes prior to disposal. Surveying of the former site buildings and of the sampling locations will be directed by WESTON. All field activities will be conducted in accordance with the methodology established by the Environmental Services Division of EPA as described in the Environmental Investigations NOA/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-2 12/98 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt Rl(FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Standard Operating Procedures and Quality Assurance Manual of May 1996. Specific data collection procedures are described in the Field Sampling Analysis Plan (FSAP) and the Quality Assurance Project Plan (QAPP). 4.4.1 Site Preparation During the initial site visit with EPA, WESTON found that severaJ'large trees had fallen across the road and that certain portions of the road are in disrepair. Prior to investigative efforts at the Reasor Chemical site, WESTON will make arrangements for the roads leading into and around the site to be cleared of debris to facilitate site access. During this time, WESTON will also arrange to have a mobile office established along the site access road and supplied with electricity and telephone service. Portable septic facilities and solid waste disposal service will also be arranged. WESTON will also procure and direct North Carolina registered surveyors to reestablish the locations of former Reasor Chemical buildings, and other significant site features (e.g., drums, ponds, tanks, etc.) to allow for preparation of an accurate site map and assist in accurate documentation of sample locations. The locations of former site facilities (i.e., buildings) will be based on aerial photographs and other available records. It may be necessary to clear small trees or brush from some locations to facilitate surveying and sampling activities. During the site preparation phase, WESTON will attempt to establish the locations of the aboveground product piping system previously located on-site and locations of the observed remnants of the system will be documented by the surveyors. WESTON will also attempt to locate the reported four production wells used at the site during previous operational activities. NOA/I<:\ WP\ 04400\ 077\ WPMAT00 1. WP 4-3 12/96 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 The wells will be located using maps of the Reasor site from the period of active operations as well as electromagnetic surveying methods. The electromagnetic surveying method will also be used to determine if drums or other items may be buried underground at the drum disposal area and other investigation areas. 4.4.2 Well Survey As part of a review the results of the residential well survey completed by the State of North Carolina during the Site Investigation (SI) of 1994, WESTON will verify the location of each residential well described in the SI report and will examine a one-half mile perimeter surrounding the site for any additional or new residential or commercial wells. If new wells are located, WESTON will try to ascertain construction specifications from the owner of the well and will locate the well on maps of the area surrounding the site. The well verification survey will be conducted on a drive-by basis. 4.4.3 Geoprobe® Groundwater and Soil Investigation Review of historical information from the Reasor Site indicates a strong potential for groundwater and subsurface contamination beneath the site. To determine if groundwater contamination exists beneath the site, WESTON has developed a three phased approach. Phase I will include installation of 14 direct push technology or Geoprobe® borings at various locations on the site. The purpose of these _borings is to establish the groundwater flow direction beneath the site and determine general groundwater quality on and around the site. The Phase I groundwater sampling will be part of a larger field effort to canvass the site and collect samples I and data from several matrices, including soil, surface water, and sediment. I NOR/K: \ WP\ 04400\ 077\ WPMAT001 .WP 4-4 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Phase II will include the installation of up to 25 additional Geoprobe® borings. The pmpose of these borings is to more clearly define the source and extent of groundwater contamination beneath the site based upon the groundwater flow direction, general groundwater quality, and significant source areas established by the Phase I data. Phase III will include the installation of up to 12 permanent monitor wells. The purpose of these wells is to complete definition of the groundwater contaminant plume (if present) based on the Geoprobe® investigation. Six Geoprobe® borings are also proposed for installation if a groundwater plume is detected and the plume is suspected to have migrated off-site. 4.4.3.1 Phase I Geoprobe® A detailed description and justification of the Phase I Geoprobe® borings is provided below. Phase I groundwater sampling will include collection of 28 groundwater samples from 14 Geoprobe® boring locations (Figure 4-1). Two groundwater samples will be collected from each of the Geoprobe® borings. The first sample will be collected from the top of the water table, which is expected to be within the local regolith aquifer. The second will be collected from the top of the Castle Hayne Limestone formation (estimated depth 28 ft bis). The location and justification of the 14 Geoprobe® points are provided in the following table. NOR/I<:\ WP\ 04400\ 077\ WP MA TOO 1 . WP 4-5 12/96 1------------------------------~ I I I I I I I I I SOURCE: KUC[RA INT. AERIAL PHOTOS, REAL PROPERTY t.C OF CAPE FEAR. LAW OMRONt.lDHAL INC. SITE I.CAPS NORlll TANK CRADLE AAtA LABORATORY PROPER1Y LINE PLT. SC. FILE NO. WOODED AREA A?f'ROXMA TE M:n..AOO UUITS REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA PHASE I GEOPROBE INVESTIGATION - GROUNDWATER AND SOIL SAMPLING LOCATIONS FIGURE 4-1 DRA\JN SLUICE AREA WRS ' I I ' I · LEGEND l8l GEOPROBE BORING LOCATION- GROUNDWATER AND SOIL SAMPLING LOCATION \ ~ , \ 200· 400' SCALE FEET DES. ENG. DATE APPROVED DATE V. 0. NO, 04400-077 Dw'G. NO, 04400-03 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F, Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Number of Boring Location Borings I Immediately south of former garage location I Immediately east of junction of site access road and site perimeter road I Central portion of southern end of perimeter road I Eastern poition of southern end of perimeter road I Adjacent to fonner transfonner bank I Central portion of eastern end of perimeter road I Within former Sluice Area I Central portion of northern end of perimeter road I Western portion of northern end of perimeter road I Central portion of western end of perimeter road I Adjacent lo former tank cradle area at the northwestern edge of the site I South of former process extractor location I Within former scrap electrical wire burning area I Within former drum disposal area NOR/K: \ WP\ 04400\ 077\ WPMAT00 1 . WP Draft Rl/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Purpose of Boring Collect sample of soil and groundwater near former garage location to determine if potential contamination exists Determine if contaminant plume exists in this area and direction of groundwater flow across site Determine if contaminant plume exists in this area and direction of groundwater flow across site Determine if contaminant plume exists in this area and direction of groundwater flow across site Collect soil and groundwater samples to determine if potential contamination exists; aid determination of groundwater flow across site Determine if contaminant plume exists in this area and direction of groundwater flow across site Determine if site activities have contributed contaminants to soil and/or groundwater in this area Determine if contaminant plume exists in this area and direction of groundwater flow across site Determine if contaminant plume exists in this area and direction of groundwater flow across site Determine if contaminant plume exists in this area and direction of groundwater flow across site Collect soil and groundwater samples to determine if potential contamination exists from past activities and detennine direction of groundwater flow across site Collect soil and groundwater samples lo determine if potential contamination exists from past activities and determine direction of groundwater flow across site Collect soil and groundwater samples to determine if potential contamination exists from past activities and determine direction of groundwater flow across site Collect soil and groundwater samples to determine if potential contamination exists from past activities and determine direction of groundwater flow across site 4-7 12/98 I I I I I I This document was prepared by Roy F. Weston, lnc., expressly for E=PA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Groundwater samples collected during Phase I activities will be analyzed for several analytes. These include VOCs, semivolatile organic compounds (SVOCs), metals (RCRA list only), and pesticides/PCBs. A total of eight groundwater samples (four from the top of the water table and four from the top of the Castle Hayne) will be analyzed for the entire suite of analytes listed above. The eight samples include two upgradient samples, two downgradient samples, and four I samples from within the central portion of the site. All other groundwater samples will be I I I' I I I I I I I I analyzed for VOCs and SVOCs only. Groundwater samples collected from the former scrap electric wire burning area, the former pipe shop location, and the former garage location will also be analyzed for metals content. Soil samples collected during the Phase I effort will be analyzed for the same constituents as that of groundwater, and of these samples, four will be analyzed for the entire suite of analytes. The four full scan samples will be collected from the following locations: one upgradient location, one downgradient location, and two locations within the central portion of the site. All other samples will be analyzed for VOC and SVOC content only with the exception of samples collected from the former scrap electric wire burning area, the former pipe shop location, and the fonner garage location. These samples will also be analyzed for metals content. All of the Phase I Geoprobe® locations will be used to detennine the direction of groundwater flow across the site. This will be accomplished through the installation of temporary, one and one-half inch PVC screen and casing into the Geoproboo boreholes. Once installed, the elevation and location of the top of the PVC casing will be measured by a registered surveyor. These data will be used to determine the elevation of the groundwater table and, subsequently, the direction of groundwater flow across the site. Groundwater samples will be collected from each location NOA/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-8 12/96 I I I, I I I I I I I I' I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 after the surveying has been completed. After the groundwater samples have been collected, the PVC will be removed so that the boring can be continued to the top of the Castle Hayne. During the installation of each Geoprobe® boring, soil samples for geologic and hydrogeologic characterization will be collected continuously from the surface to boring termination depth. The tennination depth will be determined by the on site WESTON geoscientist based upon data collected during the investigation. One soil sample from the unsaturated zone of each boring wilJ be collected for laboratory analysis. To determine which sample will be submitted for analysis, all unsaturated soil samples will be scanned with an Organic Vapor Analyzer (OVA) to determine if volatile organic compounds (VOC) are present. In addition to the scanning, each sample will be reviewed by the on-site WESTON representative for any staining or other indications of contamination. All Geoprobe® boring locations completed during each phase of work will be backfilled to surface with pure sodium bentonite pellets. 4.4.3.2 Phase II Geoprobes® Phase II groundwater sampling will include the instalJation of up to 25 Geoprobe® borings with the collection of up to 50 groundwater samples (Figure 4-2). The groundwater samples for Phase II will be collected from the same zones as described for the Phase I investigation (i.e., top of the water table and top of the Castle Hayne. The proposed locations of these Geoprobe® borings are described below: NOA/K:\ WP\ 04400\ 077\ WPMATOO 1 . WP 4-9 12/96 l~---------=--------------------------i I I I I I I I I I I I I I OGARACE: SClJRa'., l<UaRA !MT. ADllAL A-IOTOS, RE.AL PRCPERTY M C:F CAP£. FENt. LAW Ol\ftCMENTAL INC. 9TE M#>S : : . . . . r f f lR1JO< SCALE I ORUt.l OISPOSAL IM.A NORTH TAMI< CRADLE AAf.A L.ABORATORY PROPERTY UNE PLT. SC. FILE NO. WOODED AREA - APPROXMAT[ '111£TlAHD \.MTS REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA PHASE II GEOPROBE INVESTIGATION - GROUNDWATER AND SOIL SAMPLING LOCATIONS FIGURE 4-2 DRA\JN SLUICE AREA WRS ' LEGEND t & NUMBER OF GEOPROBE BORINGS TO I BE INSTALLED 'MTHIN GIVEN AREA I , (ACTUAL BORING LOCATIONS 'MLL BE DETERMINED DURING FIELD INVESTIGATION.) I 200· SCALE DATE 12-96 DATE APPROVED I/:,. 'fl 400' FEET DATE 1,1, □. NO. 04400-077 D\IG, ND. 04400-05 I I I I I I I I I I I I I I I I This document was prepared by Roy F._Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission_of EPA. Number of Boring Location Borings I Adjacent to former garage location I Adjacent to pipe shop 2 Adjacent to the two small ponds at the southeastern end of the site -Ponds I and 2 3 Along extraction process line 2 Adjacent to the former refinery area I Adjacent to the fonner laboratory location 2 Adjacent to the former Rosin Warehouse location 2 Adjacent to the former tank cradle area at the northwestern end of the site 2 Adjacent to former location of work tanks and still 2 Within the drum disposal area 2 Adjacent to former Pond No. 4 2 Adjacent to the former. Settling Pond 2 Within the former location of the Sluice Area . NOR/K: \ WP\ 04400\ 077\ WPMAT001. WP Draft RI/FS Work Plan Reasor Chemical Company Site Section; 4 Revision: 0 Date; January 1997 Purpose of Boring Determine if groundwater contamination is present underneath the former garage location and define direction of groundwater flow across site Determine if groundwater contamination is present underneath the former pipe shop location and define direction of groundwater flow across site Determine if past discharges to these ponds has affected groundwater quality and define groundwater flow direction across site Detennine if past activities along the extraction process line has affected groundwater quality and define groundwater flow direction across site Determine if past activities at the refinery affected groundwater quality and define groundwater flow direction across site Determine if past activities at the laboratory affected groundwater quality and define groundwater flow direction across site Determine if past activities at the rosin warehouse affected groundwater quality and define groundwater flow direction across site Detennine if potential groundwater contamination exists underneath this area Determine if past activities at this location have affected groundwater quality and define groundwater flow direction across site Determine if past dumping activities affected groundwater quality underneath this area and define groundwater flow direction across site Detennine if past discharges to this pond affected groundwater quality and define groundwater flow direction across site Determine if past discharges to this pond affected groundwater quality and define groundwater flow direction across site Determine if past dumping activities affected groundwater quality uilderneath this area and define groundwater flow direction across site 4-11 12/96 I I I I I I I I I ' I· I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. Jt shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 The final locations of the Phase II Geoprobe® borings will be determined by analysis of all soil, groundwater, surface water, and sediment data collected during the Phase I work. For certain locations, specifically, the former garage location, northwest tank cradle area, drum disposal area, and sluice area, the collection of additional groundwater samples will be determined by the groundwater sample analysis results of Phase I. Groundwater samples collected during the Phase II activities will be analyzed for VOCs and SVOCs. At least two samples will also be analyzed for metals and pesticides/PCBs. The determination of which two samples will be analyzed for the full suite of analytes will be made after the data from Phase I has been analyzed. In addition, up to four samples may be analyzed for metals content. The determination of the final number of samples and the locations from which these samples will be collected will be decided after review of the Phase I data. Unsaturated soil samples for laboratory analysis will be collected from approximately 13 of the Phase II Geoprobe® borings. The locations from which these samples will be collected will be based upon the soil and groundwater sample analytical data collected during the Phase I investigation. Soil samples for geologic and hydrogeologic characterization will be collected continuously from each boring during the Phase II investigation. 4.4.3.3 Phase m Geoprobes® Phase ill groundwater samples will be collected only in the event that groundwater contamination has been determined to be beyond the perimeter road. The Phase ill work will NOR/K:\ WP\ 04400\ 077\ WPMATOO 1 .WP 4-12 12/98 I I I ,_ I I I I I I I: This document was prepared by Roy F. Weston, Inc., expressly for EPA lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 include up to 6 Geoprobe® boring locations with the collection of up to 12 groundwater samples. The samples will be collected from the same hydrologic zones as in Phase I and IL The Phase Ill Geoprobe® boring locations will be analysis and interpretation of data collected in Phases I and Ill. Soil samples for geologic and hydrogeologic characterization will be collected in the same manner as that for the Phase I and Phase II investigations. Unsaturated soil samples for will be submitted for analysis based upon screening of the samples with an OVA and visual inspection of the samples for evidence of staining or other indications of contamination. The analytical parameters of groundwater and soil samples collected during Phase Ill activities will be determined after analysis of data from Phase I and II activities. At least two samples may be analyzed for the full suite of parameters. 4.4.4 Surface Soil Investigation As part of the Phase I field effort, WESTON will collect surface soil samples from the on-site areas of concern (Figure 4-3). This sampling effort is designed to: (1) determine if contaminants are present in the areas of concern; (2) concentration of contaminants (if present); and (3) horizontal extent of contamination within each area of concern. Composite surface soil samples will be collected from O to 2 feet below surface using hand augers. The number of samples collected and corresponding analytes within each area of concern are presented in the following table. NOA/K:\ WP\04400\077\ WPMAT001.WP 4-13 12/98 1.------------=-----------------c----------i 11 I I I I I I I I I I I I i SOOACC, KUCl:RA INT. NJaAL PHOTOS. REM.. PROPERTY M CF c.N"E FEAR. LAW Ol~TAL. INC. SITE MAPS . . . . . : / TRVCI( SC>.1..£ I DRUI.I DISPOSAL AAEA NOR1H TAM< CRAOLE AREA pROPERiY LINE PLT. SC. FILE NO. WOODED AREA APPROXIMA T[ 'll'EllANO LIMITS REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA SURFACE SOIL SAMPLING LOCATIONS FIGURE 4-3 SLUICE AREA DRA\JN WRS CHECKE#,l/ ' LEGEND f ·, & NUMBER OF SOIL SAMPLES TO BE · , COLLECTED WITHIN GIVEN AREA I \ (ACTUAL SAMPLING LOCATIONS WILL BE . DETERMINED DURING FIELD INVESTIGATION.) , \ 200· SCALE DATE DES. ENG. . 12-96 APPROVED 400' FEET DATE \,/, □. ND. 04400-077 D\IG, NO. 04400-04 I I I I I I I I 'I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Area of Concern Former garage location Fonner Pipe Shop Former Transformer bank Former Chip Processing/Extraction Area Former Refinery location Former Laboratory location Former Electric Wire/Scrap Copper area Former Work tanks and Still location Drum Disposal area Northwestern Tank Cradle area Former Rosin Warehouse location Sluice Area Number of Samples 5 5 5 20 10 8 8 10 IO IO 8 12 Draft RJ/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Analytical Parameters VOCs, SVOCs, Metals VOCs, SVOCs, Metals voes, PCBs voes, svocs VOCs, SVOCs voes, svocs Metals, SVOCs VOCs, SVOCs voes, svocs VOCs, SVOCs voes, svocs voes, svocs At least one sample from each area of concern will be submitted for full analytical parameter analysis. A total of three background surface soil samples will be collected from three separate areas around the site considered to be unaffected by previous site activities. Each of the background samples will be submitted for full scan analysis (i.e, VOCs, SVOCs, metals, pesticides, and PCBs). Soils not collected from a boring for laboratory analysis will be used to backfill the borehole. Surface soil sample locations will be marked with a colored pin flag. NOR/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-15 12/98 I I· I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 4.4.5 Sediment Sampling Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 As part of Phase I site activities, up to 23 sediment sampling locations will be collected from the locations shown in Figure 4-4. The purpose of the sediment sampling is to attempt to define potential contamination within on site drainage ditches and ponds as well as off-site drainage ditches, small streams, creeks, and swamps. The sediment sampling sites include: • An upgradient location at the northwestern edge of the site • Eight separate locations within the on-site drainage ditches. • Two locations within the settling pond at northeastern end of the site • Two locations within South Pond No. 1 • Two locations within South Pond No. 2 Two locations within the drainage pond in the central portion of the site • • • • • A single location within the drainage ditch that emanates from the sluice area One location within a small stream emanating from the eastern edge of the site Two locations within the Prince George Creek Two locations within the swamp on the north border of Prince George Creek All sediment samples will be analyzed for VOC and SVOC content. The upgradient location, the two locations within Prince George Creek, and the location at the southwestern end of the on site drainage ditches will be analyzed for the full analyte list. 4.4.6 Surface Water Sampling Surface water present on and off-site will also be sampled during the Phase I activities. Depending upon water availability, up to fourteen sampling locations will be established (see Figure 4-4). Approximately two thirds of the samples will be collected from on site locations, NOA/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-16 12/96 I I I I I I I I I I I I I I I SOUR«, KUC(RA INT. AERIAL PHOTOS. REA1. PROPERTY t.lAP Of CAPE FEAR. L>,W EN'v1RONMDHAL INC. SIT[ MAPS "' 'V 'V "' WOODED AREA pROPERn' UNE >PPROXIMATE l'IETI.ANO UI.IITS • "' "' PLT. SC. FILE NO. "' "' "' "' "' "' "' "' "' "' "' "' "' "' "' "' "' x.,,, 'V "' "' "' "' "' "' "' "' "' "' "' SLUICE AREA 'V "' "' "' "' • * I t I I , X "' "' "' "' . ..., '-V "' "' "' "' "' 'V "' "' REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA SURFACE WATER AND SEDIMENT SAMPLING LOCATIONS FIGURE 4-4 'V "' DRA'w'N LEGEND • PROPOSED SEDIMENT SAMPLING LOCATIONS X POTENTIAL SURFACE WATER SAMPLING LOCATIONS 0 300' 600' SCALE FEET DATE DES. ENG. DATE WRS 12 96 V. □. NO. 04400-077 CHECKED J)J),.U DATE APPROVED /, '/3 f. DATE D\t/G. NO. 04400-01 I I I I I I I I ' I I I II D This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft Rf/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 if possible. If water is not available on site, the number of samples will be reduced and the water will be collected at off-site locations as close to the site as possible. Ten percent of the surface water samples will be analyzed for the full parameter list. The remaining samples will be analyzed for VOCs and SVOCs only. 4.4.7 Residential and/or Commercial Well Sampling During the 1994 NC DEHNR SI, groundwater samples were collected from three residential wells located near the site. In an effort to verify the results of this sampling event, WESTON suggests resampling these same wells as well as any new residential and/or commercial wells that are within 1/4 mile of the site boundaries. Residential or commercial well groundwater samples will be analyzed for the full suite of analytical parameters. WESTON assumes that EPA will secure access from appropriate property owners for the residential well sampling program. 4.4.8 Permanent Monitor Wells In order to continue long term monitoring of the groundwater underneath the site, WESTON will install up to twelve permanent monitor wells on and around the site (Figure 4-5). The monitoring system is designed to provide long term groundwater data from upgradient, downgradient, and on site locations. Approximately nine of the monitor wells will be installed at the top of the water table (also referred to as th~ shallow wells) and three wells at the top of the Castle Hayne Limestone formation. The total number of wells and the final locations of the wells will be determined after review of the data collected during Phases I, II, and ill (if needed). NOR/K;\ WP\ 04400\ 077\ WP MA TOO 1. WP 4-18 12/96 I I I I I I I I I I I I I I I SOURCE: KUCERA fH. AERIAL PHOTOS, REAL PROPERTY tr.t ~ CAPE FEAR. LAW (N...,RONMOITAL INC. sm: MA.PS PLT. SC. FILE NO. - ----ORUM DISPOSAL AAEA NORlli T>-NK CRAOl.£ AREA LABORATORY WOODED AREA - ---- APPROXllrilA TE \11£Tl.ANO U.CITS REASOR CHEMICAL COMPANY CASTLE HAYNE, NORTH CAROLINA PERMANENT MONITOR WELL LOCATIONS FIGURE 4-5 SLUICE A~EA ' I \'. , \ -iv 0 LEGEND MONITOR WELL LOCATION TO BE INSTALLED AT TOP OF CASTLE HAYNE FORMATION 0 MONITOR WELL LOCATION TO BE INSTALLED AT AND THROUGH THE TOP OF WATER TABLE (LOCA llONS ARE APPROXIMATE. ACTUAL LOCATIONS WILL BE DETERMINED AFTER REVIEW OF DATA GATHERED DURING THE FIELD INVESTIGATION.) 200' 400' SCALE FEET DRA\IN WRS CHECKE~.j),{.) APPROVED DATE IJ. □. NO. 04400-077 DVG. NO. 04400-02 I I I I I I I' I I I I I 1: I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RljFS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 All monitor wells will be installed using hollow stem auger techniques. Each shallow well will be installed using ten feet of stainless steel screen and the appropriate amount of stainless steel riser pipe. The deep wells will be installed using 5 ft screen. The width of opening or slot size of the screen will be determined after examination of the grain size of aquifer materials. The aquifer materials will be collected during the Geoprobe® investigation and processed through sieves during the field investigation. During the installation of the monitor wells, well constrnction materials, i.e., bentonite pellets, sand, cement, and potable water, will be sampled for VOC and SVOC content. Installation techniques and specifications of each well are discussed further in the Field Sampling and Analysis Plan (FSAP). ,After completion of the installation of the monitor wells, WESTON will develop each well according to parameters outlined in the FSAP. The monitor wells will be sampled within one week after development has been completed, Details of the sampling process are outlined in the FSAP. During the sampling process, each monitor well will be surveyed for horizontal and vertical location according to the North Carolina State Plane Grid. Water level measurements collected during the sampling process will be converted to elevations after the survey has been completed. The groundwater elevations, in conjunction with data from the Geoprobe® investigation, will be used to generate a potentiometric map for the site. 4.4.9 Aquifer Testing Rising head slug tests will be perfom1ed on each of the new permanent wells installed at the Reasor site in accordance with the methodologies described in Section 3 of the FSAP. Wells will be selected for slug testing such that the variability in subsurface conditions is represented. The rising head water level data will be recorded electronically and downloaded to a personal NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1 .WP 4-20 12/86 I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 computer (PC) to be evaluated in accordance with Bouwer & Rice methodologies for unconfined aquifers. These data will be utilized along with analytical data to evaluate potential fate and transport of constituents of concern at the site. 4.4.10 Former Water Supply Wells During the Phase I investigation WESTON will also attempt to locate the forn1er water supply wells reportedly located at the Reasor site. The well search will be conducted using visual inspection of the suspected locations. If the wells cannot be located through visual inspection, geophysical equipment will be mobilized and used to search for the former wells. If the subject wells are located, then WESTON will attempt to obtain water levels and collect groundwater samples for voes, SVOes, metals, and pesticides/PeBs. 4.4.11 Investigation Derived Waste All residuals from the well installation, including soil cuttings, paper, plastic, water, etc., will be containerized on site and segregated according to type. All solid waste, i.e., paper, plastic, etc., will be placed into trash bins for disposal at a local landfill. All soil cuttings will be placed onto plastic sheeting for temporary storage before confirmatory sampling for hazardous constituents, including voes and SVOes. If analysis of residual soil samples does not reveal any contaminant concentrations, the soil will be disposed of on site. All water generated during decontamination, development, and sampling processes will be held temporarily in storage tanks that have been brought to the site. The water will be processed through 55-gallon drums containing activated carbon in order to remove any voe and svoe contaminants. After processing the water through the carbon containing drums and prior to disposal, the water will NOA/ K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-21 12/98 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 be sampled for verification of VOC and SVOC content. If no contaminants are present, this water will be released to the U-shaped settling pond. 4.5 SAMPLE ANALYSIS/VALIDATION 4.5.1 Sample Analysis Chemical analysis of Analytical Level IV samples will be performed following the current EPA Superfund Contract Laboratory Program Statement of Work for Multi-Media, Multi- Concentrations Organics and Inorganics. Chemical analyses of Analytical Level III samples will be conducted in compliance with the requirements of the analytical methods specified in the FSAP. 4.5.2 Data Validation Data validation is the process of screening data and accepting, rejecting, or qualifying its usefulness on the basis of sound criteria. Data will be validated, as appropriate, based on holding times, initial calibration, continuing calibration, blank results, and other QC sample results. This will be performed by the EPA Region IV Laboratory Evaluation/Quality Assurance Section. The field team leader will review all field documentation for completeness, legibility, consistency, and reasonable agreement with expected or typical results. Extreme, anomalous, or seemingly unreasonable results will be accepted only after the accuracy of the measuring I instrument has been verified by one or more additional measurements delivering a similar I NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1.WP 4-22 12/96 I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 response. If data fails to meet calibration criteria or data quality objectives, the instmment will be tagged as out-of-service. 4.6 ENVIRONMENTAL FATE AND TRANSFER MODELING EVALUATION Data collected during the field investigation, including site physical characteristics, source characteristics, and extent of contamination, will be used to generate analyses of contaminant fate and transport. Typically information on contaminant release history is available. As a result, the observed extent of contamination may be used in assessing the transport pathway's rate of migration and fate of contaminants over a period between release and monitoring. If information on contaminant release history is not available from the Reasor Chemical site, contaminant fate and transport will be estimated on the basis of site physical and source characteristics. Applicable data will be compiled and entered into computer models for design of the fate and transport regime. Information generated from the model will be placed onto maps and other diagrams, and presented within the RI report. A discussion of significant mechanisms in the subsurface will be presented along with a discussion of findings from the Reasor modeling effort. 4. 7 BASELINE RISK ASSESSMENT DEVELOPMENT WESTON will provide a Baseline_ Risk Assessment to EPA consisting of both human health and I environmental/ecological risk assessments. This baseline risk assessment will identify and summarize chemicals of potential concern (COPC), evaluate potential human and ecological I exposure, characterize the toxicity and effects of the COPC present at the site, describe their fate I NOA/ K:\ WP\ 04400\ 077\ WPMATOO 1. WP 4-23 12/98 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 and transport, and assess potential risk on human health and the ecological environment (including both flora and fauna). The procedures required to perform the human health and ecological risk assessment will follow the general guidance provided by the Superfund Program and Supplemented by EPA Region IV (EPA, 1989; 1991a,b; 1992a,b; 1995a,b; 1996). EPA may also identify other guidance for the ecological assessment as necessary. WESTON will also identify applicable or relevant and appropriate requirements (ARARs) and develop preliminary remediation goals (PRGs) for human health pathways. A Technical Memorandum describing the results will be submitted to EPA Region IV 14 days after the Work Plan is finalized. However, it should be emphasized that only · when the data from the RI are received by WESTON can the final list of chemicals of concern be ascertained. 4.7.1 Human Health Risk Assessment The human health risk assessment will consist of the following components: • • • • • Data Collection and Evaluation Exposure Assessment and Documentation Toxicity Assessment and Documentation Risk Characterization Analysis NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1 .WP 4-24 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA it shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 4.7.1.1 Data Collection and Evaluation Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 EPA will provide WESTON with QNQC validated laboratory data generated during RI activities at the site. WESTON assumes that the data will be provided on diskette m a standard spreadsheet fornrnt in numeric values (i.e., Lotus, Excel). The data needs to include all appropriate parameters necessary for data summarization (i.e., quantitation limits, units). WESTON will review the available information and shall identify the chemicals of potential concern (COPC) in each medium. A Technical Memorandum will be submitted to discuss the COPCs and their environmental pathways. In addition, a brief summary of ecological concerns will be addressed. The following guidelines, in accordance with EPA (1989a) and Region IV guidelines (EPA, 1991b, 1995a) will be used in the data evaluation: • • • If data are qualified as diluted or estimated, they will be used as presented . If a sample is duplicated, the data from the two duplicates will be averaged . All J-qualified data are assumed to be valid data and will be used . The data summaries for each medium will be tabulated to show for each chemical: • • • • • • • Detection frequency Range of detection limits Arithmetic average of background concentrations Arithmetic average of detected concentrations Detected concentrations range Risk-based screening value Basis for elimination of selection as a COPC NOA/K:\ WP\04400\ 077\ WPMATOO 1. WP 4-25 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 The rationale for elimination or selection of a chemical as a COPC will be in accordance with EPA (1989) and EPA Region IV guidelines (EPA, 1995a): • • • Comparison of the maximum on-site detected concentrations with the risk-based concentration table. Those chemicals exceeding the risk-based concentrations will be retained in the risk assessment. Comparison of naturally occurring inorganic compounds maximum detected concentrations to 2 times the average site-specific background concentration. • Screening on-site media for essential nutrients. For each medium, the selected COPC will be retained and summarized for further risk evaluation in the baseline risk assessment. 4.7.1.2 Exposure Assessment and Documentation Potential current and future land and water uses will be evaluated for the site in order to develop reasonable maximum exposure (RMB) scenarios for potentially exposed populations. Potentially exposed populations which may be evaluated for the site include current trespassers, future residents, and future workers. For each population or receptor identified at the site, an analysis of potential exposure pathways will be made. This analysis will include an evaluation of: • • • • Chemical sources and releases (leaching of chemicals from soil into groundwater) Transport media (i.e., groundwater, surface water, air, soils, sediments) Exposure points (sluice area, creek) Exposure routes (i.e., ingestion, inhalation, dermal absorption) NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 4-26 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Dratt RlfFS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 Quantification of potential exposure will be made by estimating potential exposure concentrations and calculating exposure doses. In most cases, exposure concentrations will be estimated using analytic data generated during the RI at the site, and the upper 95 % confidence limit of the mean will be used as an exposure concentration. If the calculated upper 95 % confidence limit of the mean exceeds the maximum detected value, the maximum detected value will be used in the exposure calculations. • If a chemical is not detected in a particular sample, then one-half of the sample quantitation limit will be used as the value for that sample. Exposure concentrations, as well as a number of other exposure assumptions, are used as inputs into exposure dose models. These models are used to estimate exposure doses in milligrams chemical/kilograms body weight/day for each exposure route. 4.7.1.3 Toxicity Assessment and Documentation The toxicity assessment discusses the potential for the COPCs identified to cause adverse health effects in exposed individuals and presents the chemical-specific quantitative dose-response data for the COPCs. WESTON will use information in EPA's Integrated Risk Information System (IRIS) (EPA, 1996) and EPA's Health Effects Assessment Summary Tables (HEAST) (EPA, 1995c) to identify toxicity values, reference doses (Rills) for the evaluation of noncarcinogenic health effects, and cancer slope factors (CSFs) for the evaluation of carcinogenic effects of the chemicals of potential concern. In addition, toxicity values for dermal exposures will be derived NOR/K;\ WP\ 04400\ 077\ WP MA TOO 1. WP 4-27 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 based on information in Region IV EPA's risk assessment guidance for Superfund (EPA, 1995a). If a toxicity value is not available, WESTON will contact EPA for guidance and discussion of approach to derive these numbers. The toxicity section shall include tables which summarize the weight of evidence and CSFs for carcinogenic chemicals, and RIDs for noncarcinogenic chemicals. The infonnation collected during the toxicity assessment will be fonnatted according to Region IV guidelines (EPA, 1995a). 4.7.1.4 Risk Characterization WESTON will integrate data from both the exposure and toxicity assessments to quantify the current and future health risks associated with the chemicals of potential concern at the site. This section of the report will contain the following: • Identify the chemicals of concern -chemicals of concern (COCs) are the chemicals of potential concern (COPCs} that significantly contribute to a pathway in a use scenario for a receptor that either (a) exceeds a 104 cumulative site cancer risk; or (b) exceeds a noncarcinogenic hazard index (Ill) of I (EPA, 1995a). • Quantification of potential risks for each identified chemical of concern and for each exposure route. • • Integration of risks across chemicals and exposure routes that affect the same individual over the same time period. Assessment of uncertainty factors involved with risk assessment (this will be a summary of the uncertainties presented in previous tasks). NOR /K: \ WP\ 04400\ 077\ WPMATOO 1. WP 4-28 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express wri~en permission of EPA. 4.7.1.5 Carcinogenic Risk Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 Carcinogenic risk, which is the risk posed to an individual over a lifetime of exposure, will be calculated for each chemical through each exposure route using the following equation: Cancer Risk = LADD x CSF Where: Cancer Risk = Lifetime carcinogenic risk (expressed as a probability). LADD = Lifetime average daily dose (averaged over 70 years) (mg/kg-day). CSF = Cancer slope factor (mg/kg-dayt1• The total cancer risk posed by all carcinogens and exposure routes associated with each medium is the sum of the chemical and route-specific cancer risks. A final total cancer risk will be determined for each scenario across all appropriate media. 4.7.1.6 Noncarcinogenic Risk Noncarcinogenic risks will be evaluated by comparing predicted chemical daily intakes, which were averaged over the period of exposure, to reference doses (RfDs) as illustrated in the following equation: HQ= ADD/RID Where: HQ= Hazard quotient. NOR /K:\ WP\ 04400\ 077\ WPM A TOO 1 .WP 4-29 12/98 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc,, expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 ADD= Average daily dose (averaged over the exposure period) (mg/kg- day). RID= Reference dose (mg/kg-day). The hazard quotients will be summed to determine the hazard index (HI) for each chemical for each exposure route and for each exposure scenario (all chemicals and exposure routes combined). If hazard quotient or hazard index exceeds unity, this indicates a potential risk to an adverse effect from that chemical(s) through that exposure route(s). 4.7.1.7 Risk-Based Remedial Options Remedial Goal Option (RGOs) will be calculated for the chemicals of concern. This section will contain a table of media-specific cleanup levels for each COC in each land use scenario. The list of COCs is generated at the conclusion of the risk characterization section. The table will identify cleanup levels for 10-6, 10-5, and 104 cancer risk levels for each ·carcinogenic COC. In addition, the table will identify cleanup levels for each noncarcinogenic COC at HQ levels of 0.1, 1, and 3 (EPA, 1995a). The purpose of this table is to provide the risk manager with a range of risk-related media levels as a basis for developing remediation actions during the feasibility study and proposed plan or the corrective measures study. 4. 7 .2 Environmental/Ecological Risk Assessment A report describing potential environmental/ecological risks from exposure to site contaminants will be submitted. The procedures required to perform the ecological risk assessment follow the general guidance provided by EPA (EPA, 1989b; 1992; 1995b). The general approach used to NOR/ K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 4-30 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 estimate potential ecological effects follows that used in the human health assessment, and includes data evaluation, exposure assessment, toxicity assessment, and risk characterization. 4.7.2.1 Data Evaluation The evaluation of data as proposed under the human health risk assessment, including the general process for selection of chemicals of concern, will also be used for the environmental/ecological assessment; however, because of the different toxicity of some chemicals to fish and wildlife as compared with human receptors, the chemicals of concern for the environmental/ecological assessment may differ from those evaluated in human health risk assessment. Thus, if applicable, a revised list of chemicals of potential concern will be submitted for the environmental/ecological risk assessment. 4.7.2.2 Exposure Assessment The objectives of the exposure assessment include the following: • • • • Identify significant pathways/routes of exposure . Identification of habitats that have received or may receive chemicals from the site. Identification of the organisms, populations, and/or communities that may be potentially exposed to the contaminants of concern at the site. Selection of target species and/or communities . NOR/K:\ WP\ 04400\ 077\ WPMAT00 1. WP 4-31 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 • Estimation of exposure point concentrations. • Prediction of exposure doses for the selected target species . The initial step in the exposure assessment will be to identify the habitats on or near the site that may be affected by site chemicals. Factors that will be considered in this evaluation include the location of chemical sources, prediction of chemical migration and persistence, local topography, local land and water uses, and the location of terrestrial and aquatic habitats in relation to chemical distribution and potential migration at the site. This infom1ation serves as the basis for choosing receptor organisms, or target species, for those habitats. Target species will be chosen for evaluation in the ecological assessment based on a number of criteria which include: • • • • • • Species that are threatened, endangered, or of special concern . Species that are valuable for recreational purposes . Species that are important to the well-being of either or both of the above groups . Species that are critical to the structure or function of the ecosystem which they inhabit. Species that are sensitive indicators of ecological change . Species for which reasonable prediction of exposure and consequent risk is possible. To help identify potential target -species at this site, information will be obtained from a site visit, published reports, and/or from contacts with state and federal resource trustees (Natural Heritage Database, U.S. Fish and Wildlife Service, state game/fish commissions). There are some instances where the selection of target species will not be necessary, such as when media- NOA/K;\ WP\ 04400\ 077 \ WP MA TOO 1. WP 4-32 12/98 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 specific criteria which protect a large percentage of species are available (e.g., water quality criteria), or when available toxicity data are not sufficient to justify a species level analysis (e.g., plants). An analysis of potential exposure routes/pathways will be made for each of the target species. All exposure routes of little or no concern based on an analysis of site characteristics will be eliminated. Focus will be given to those pathways and species considered critical to the evaluation of ecological risk at the site. 4.7.2.3 Toxicity Assessment The toxicity assessment characterizes the toxicity of the chemicals of potential concern to ecological receptors. Scientific literature and regulatory guidelines will be reviewed for medium- specific and species-specific toxicity data. Some of the databases and screening tools reviewed may include: • • • • • • • • • Aquatic Information Retrieval (AQIBRE) Quantitative Structure Activity Relationships (QSAR) database Hazardous Substances Database (HSDB) ENVIROFATE database Integrated Risk Information System ORIS) Registry of Toxic Effects of Chemical Substances (RTECS) Phytotox database Region IV Waste Management Division Sediment Screening Values Region IV Waste Management Division Freshwater Quality Values NOR/K: \ WP\ 04400\ 077\ WP MA TOO 1. WP 4-33 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 4. 7 .2.4 Risk Characterization Draft RI/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: O Date: January 1997 In the risk characterization, information from the exposure and toxicity assessments will be integrated in order to estimate the potential hazard or risk to the ecological receptors. 4.8 RI REPORT Following approval of the RI Work Plan, WESTON will begin implementation of the field investigation. At least two weeks prior to the enactment of field work, WESTON will notify EPA that field work will commence on a given date. After the Phase I and Phase II field work efforts have been completed, WESTON will issue a Site Characterization Summary for each completed phase of work. The Site Characterization Summary will briefly review the analytical results of investigative activities to provide EPA and WESTON with a reference for evaluating the development and screening of remedial alternatives. Additional information to be included in each summary will comprise site descriptions, brief discussions of field activities, including sampling activities and methodologies, brief review of site geologic and hydrogeologic characteristics, and a brief discussion and visual presentation of contamination in the sampled matrices. Maps of sampling locations and analytical results will be prepared for each Site Characterization Summary. Following completion of all field activities and receipt of all analytical data, WESTON will issue the Draft RI Report. The draft will be presented to EPA and ESD for review. WESTON will also use the data collected during the RI field work and presented in the Draft RI Report to begin preparation of the baseline risk assessment. The fonnat of the draft RI will follow the NOA/ K: \ WP\ 04400\ 077 \ WPMA TOO 1 . WP 4-34 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft Rl/FS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 suggested RI report format on page 3-30 of the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, October 1988. Following issuance of the Draft RI Report, there will be a review and comment period by EPA, ESD, and NCDEHNR. After receipt and review of the RI comments, WESTON will review and respond to each comment. An RI comments letter with the response to each comment will be prepared for EPA. Following issuance of the letter, WESTON will revise the RI Report for eventual submittal to EPA as the Final RI Report. 4.9 REFERENCES EPA (U.S. Environmental Protection Agency). 1985. Development of Statistical Distributions or Ranges of Standard Factors Used in Exposure Assessments. Washington, DC OHEA-E-61. EPA (U.S. Environmental Protection Agency). 1989. Risk Assessment Guidance for Superfund. Volume 1 -Human Health Evaluation Manual (Part A). Interim Final. Office of Emergency and Remedial Response. OSWER Directive 9285-0la. EPA (U.S. Environmental Protection Agency). 1989a. Ecological Assessment of Hazardous Waste Sites: A Field and Laboratories Reference. EPA (U.S. Environmental Protection Agency). 1989b. Risk Assessment Guidance for Superfund -Volume II, Environmental Evaluation Manual. EPA (U.S. Environmental Protection Agency). 1991. Summary Report on Issues in Ecological Risk Assessment. EPA (U.S. Environmental Protection Agency). 1991a. Risk Assessment Guidance for Superfund, Volume 1 -Human Health Evaluation Manual, Supplemental Guidance, "Standard Default Exposure Factors." Interim Final. OSWER Directive 9285.6-03. NOR/K:\ WP\ 04400\ 077\ WP MA TOO I. WP 4-35 12/90 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Draft RljFS Work Plan Reasor Chemical Company Site Section: 4 Revision: 0 Date: January 1997 EPA (U.S. Environmental Protection Agency, Region IV). 1991b. "Supplemental Region IV Risk Assessment Guidance." March 1991. EPA (U.S. Environmental Protection Agency, Region IV). 1992a. "New Interim Region IV Guidance." February 1992. EPA (U.S. Environmental Protection Agency). 1992b. Risk Assessment Guidance for Superfund. Volume 1 -Human Health Evaluation Manual (Part B). Development of Risk-Based Preliminary Remediation Goals. January 1992b. EPA (U.S. Environmental Protection Agency). 1995a. Supplemental Guidance to RAGS: Region 4 Bulletins, Human Health Risk Assessment. Office of Health Assessment. November 1995. EPA (U.S. Environmental Protection Agency). 1995b. Supplemental Guidance to RAGS: Region 4 Bulletins, Ecological Risk Assessment. Office of Health Assessment. November 1995. U.S. Department of Agriculture, Soil Survey. New Hanover County. North Carolina, June 1964. NOR/K:\ WP\ 04400\ 077\ WP MA TOO I .WP 4-36 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: O Date: January 1997 SECTION 5 FEASIBILITY STUDY WORK PLAN WESTON will utilize the data collected and analyzed during the RI and Risk Assessment to conduct the Feasibility Study (FS). The FS will include development and screening of an appropriate range of waste management options followed by a detailed evaluation of potential remedial action alternatives. The range of options will include, at a minimum, alternatives in which treatment is used to reduce the toxicity, mobility, or volume of the waste, but varying in the types of treatment, the amount treated, and the manner in which long-tenn residuals or untreated wastes are managed; alternatives that involve containment and treatment components; alternatives that involve containment with little or no treatment; and a no-action alternative. 5.1 DEVELOPMENT AND SCREENING OF REMEDIAL ACTION ALTERNATIVES Based on the data collected in the RI, the preliminary remedial response objectives identified during the RI will be developed more fully and finalized. General response actions, or categories of remedial action alternatives, will be selected to address each site problem area response objective. These general response actions will forn1 the basis for the technology screening. Any revisions to the remedial action objectives will be documented in a technical memorandum. To the extent applicable, the site problem(s), remedial response objectives, clean-up criteria, and general response actions will be described for individual operable units (e.g., contaminant source, groundwater contaminant plume). NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1 . WP 5-1 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or ln part, without the express written permission of EPA. 5.1.1 Identification and Screening of Remedial Technologies Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: O Date: January 1997 On the basis of technical guidance documents, general technical literature, and experience with site remediation, a list of potentialJy applicable remedial action technologies wilJ be prepared for each general response action. This list will be prepared from guidance materials, technical literature, and experience with waste treatment, construction, and site remediation. The technologies on the list will be screened with regard to practical applicability under conditions of the site, remedial response objectives, and clean-up criteria. The result wilJ be lists of specific technologies that have reasonable probability of contributing to the remediation of the site. 5.1.2 Development of Alternatives The technologies resulting from the screening will be used to develop remedial action alternatives, each of which will be developed to be capable of accomplishing the clean-up criteria for each affected medium. Each alternative will consist of one or more technologies. Technologies will be combined such that they are compatible and complete in that they appear reasonably capable of fulfilling the requirements of the corresponding general response action. Alternatives that reduce the toxicity, concentration, volume, or mobility of the contaminants will be developed as the situation allows. As required by SARA, alternatives will be developed in each of the following categories: • An alternative for treatment that would eliminate, or m1mm1ze to the extent feasible, the need for long-term management (including monitoring) at the site; NOA/ K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 5-2 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc,, expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • • Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 Alternatives that would use treatment as a primary component of an alternative to address the principal threats at the site; An alternative that relies on containment, with little or no treatment but is protective of human health and the environment by preventing potential exposure and/or by reducing mobility; and • A "no action" alternative. 5.1.3 Initial Screening of Alternatives The remedial alternatives resulting from Task 2 will be further screened to ensure that only alternatives having a reasonable probability of being found acceptable proceed to detailed evaluation. The following factors will be considered in the screening: • • Environmental Protection: Only those alternatives that have a reasonable probability of satisfying the remedial response objectives and contribute substantially to the protection of public health, welfare, or the environment will be considered further. Source control alternatives will be capable of achieving adequate control of source materials. Off-site alternatives must be capable of minimizing or mitigating the threat to public health, welfare, or the environment. Environmental Affects: Alternatives that appear to pose significant adverse environmental effects will be excluded, unless mitigating measures can be incorporated into the alternative. NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 5-3 12/98 I I I I I I :I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 Implementability and Reliability: Alternatives that appear to be extremely difficult to implement or do not appear to be capable of achieving the remedial objectives in a reasonable time period will be eliminated. • Cost: Cost will be used to discriminate only among alternatives that provide similar results. Alternatives that appear to be capable of providing results similar to other alternatives, but appear likely to be substantially higher in cost, will be eliminated. Cost will be used to discriminate among treatment alternatives or nontreatment alternatives, but not between treatment and nontreatment alternatives. Initial (capital) and ongoing (operating and maintenance) costs will be considered based on cost data available in guidance and general literature. • • Pernianence of Remedy: Pennanent remedies will be preferred over landfilling or remedies that leave waste in place, even if the cost exceeds those of other remedies. Non-permanent remedies that do not appear to offer significant advantages over permanent remedies will be eliminated. Innovative Technology Treatment and Resource Recovery: Alternatives incorporating innovative technologies will be preferred if there is reasonable belief that the innovative technology allows the alternative to offer potential for improved perfonnance or implementability and poses fewer adverse impacts than other available alternatives. Alternatives incorporating innovative technologies will not be eliminated solely because of the inclusion of the technology. NOA/K:\ WP\ 04400\ 077\ WPMATOO 1. WP 5-4 12/96 I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: O Date: January 1997 5.1.4 Initial Screening Technical Memorandum At the completion of the initial screening, WESTON will prepare and submit a technical memorandum summarizing the work performed and the results of each task above. The memorandum will include an array summary as well. Comments from EPA regarding the development of alternatives will be reported in the detailed analysis. 5.2 TASK 5 -DETAILED EVALUATION OF THE ALTERNATIVES The remedial alternatives resulting from the screening will be further developed and undergo detailed evaluation for technical, environmental and cost considerations. A description of each alternative will be prepared, consisting at a minimum of the following: • Description of the alternative and the individual technologies. • • • • Special engineering considerations required to implement the alternatives (e.g., pilot treatment facility, additional studies needed to proceed with final remedial design); Environmental impacts of proposed methods and costs for mitigating any adverse effects; Operation, mai.ntenance, and monitoring requirements of the remedy; Off-site disposal needs and transportation plans; NOR/K;\ WP\ 04400\ 077\ WPMA 1001. WP 5-5 12/96 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc,, expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • • • • • Temporary storage requirements; Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 Safety requirements for remedial action implementation (including on-site and off- site health and safety considerations); A description of how the alternative could be phased into individual operable units, if applicable. The description will include a discussion of how various operable units of the total remedy could be implemented individually or in groups, resulting in a significant improvement to the environment, savings m costs, or simplified logistics. A description of each alternative could be segmented to allow staged implementation of segments over time, if applicable. A review of off-site waste treatment, storage, and disposal facilities that are part of the alternative to ensure that the facilities are in compliance with applicable RCRA requirements, both current and proposed. Each alternative will undergo an environmental assessment. In accordance with the project SOW, the environmental assessment will include, at a minimum, an evaluation of each alternative's environmental effects, an analysis of measures to mitigate adverse effects, physical or legal constraints, and compliance with _CERCLA or to her regulatory requirements. Each alternative will be assessed in tern1s of the extent to which it mitigates damage to or protects public health, welfare, and the environment in comparison to the other alternatives. The specific considerations NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1 .WP 5-6 12/96 I I I •• I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 to be used in the assessment will be referenced to standards and criteria developed under federal or state environmental and health statutes. Each alternative will also undergo a detailed cost analysis. Estimates of initial costs and operating and maintenance costs over time will be prepared and the present-worth equivalent cost will be computed using a time-value-of-money rate (discount or interest rate) prevailing at the time or otherwise specified by EPA. The detailed evaluation of the alternatives will conform to the requirements of the National Contingency Plan, in particular, Section 300.68 (h), Subpart F, and will consist of a technical, environmental, and cost evaluation. The detailed evaluation will follow the process as specified in the "Guidance for Conducting RI/FS under CERCLA" (USEPA 1988). Nine evaluation criteria are stipulated that are to be applied in the evaluation of each alternative. Table 5-1 presents the nine evaluation criteria and the factors considered for each evaluation criterion. A brief description of each criterion follows. Short-Tenn Effectiveness This criterion addresses the effects of the alternative during the construction and implementation phase until the remedial actions have been completed and the selected level of protection has been achieved. Each alternative is evaluated with respect to its effects on the community and on- site workers during the remedial action, environmental impacts resulting from implementation, and the amount of time until protection is achieved. NOA/K:\ WP\ 04400\ 077\ WPMATOO 1 .WP 5-7 12/88 I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA • • • • • Table 5-1 Detailed Evaluation Criteria Dratt RJ/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 SHORT-TERM EFFECTIVENESS Protection of community during remedial actions Protection of workers during remedial actions Time until remedial response objectives are achieved Environmental impacts LONG-TERM EFFECTIVENESS Magnitude of risk remaining at the site after the response objectives have been met Adequacy controls Reliability of controls REDUCTION OF TOXICITY. MOBILITY. OR VOLUME Treatment process of remedy Amount of hazardous material destroyed or treated Reduction in toxicity, mobility, or volume of the contaminants Irreversibility of the treatment Type and quantity of treatment residuals IMPLEMENTABILITY COST Ability to construct technology Reliability of technology Ease of undertaking additional remedial action, if necessary Monitoring considerations Coordination with other agencies Availability of treatment, storage capacity, and disposal services Availability of necessary equipment and specialists Availability of prospective technologies Capital costs Annual operating and maintenance costs Present worth analysis Sensitivity analysis NOR/ K: \ WP\ 04400\ 077\ WPMATOO 1. WP 5-8 12/96 I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. lt shall not be released or disclosed, in whole or in part, without the express written permission of EPA. • • • • Table 5-1 (Continued) Detailed Evaluation Criteria COMPLIANCE WITH ARARS Compliance with chemical-specific ARARs Compliance with action-specific ARARs Compliance with location-speci fie ARA Rs Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 Compliance with appropriate criteria, advisories, and guidance OVERALL PROTECTION OF HUMAN HEALTH AND ENVIRONMENT STATE ACCEPTANCE COMMUNITY ACCEPTANCE NOA/K:\ WP\04400\077\ WPMAT001.WP 5-9 12/96 I, I I ,, I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Long-Tem1 Effectiveness Draft RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 This criterion addresses the results of a remedial action in tem1s of the risk remaining at the site after the response objectives have been met. The primary focus on this evaluation is to detennine the extent and effectiveness of the controls that may be required to manage the risk posed by treatment residuals and/or untreated wastes. The factors to be evaluated include the magnitude of remaining risk (measured by numerical standards, such as cancer risk levels), and the adequacy, suitability, and long-term reliability of management controls for providing continued protection from residuals (i.e., assessment of potential failure of the technical components). The long-tenn effectiveness factors cited in SARA, Section 121 (b) (I) will be addressed. Reduction of Toxicity. Mobility. and Volume This criterion addresses the statutory preference for selecting remedial actions that employ treatment technologies that permanently and significantly reduce toxicity, mobility or volume of the contaminants. The factors to be evaluated include the treatment process employed, the amount of hazardous material destroyed or treated, the degree of reduction expected in toxicity, mobility and volume, and the type and quantity of treatment residuals. Implementability This criterion addresses the technical and administrative feasibility of implementing an alternative and the availability of various services and materials required during its implementation. Technical feasibility considers construction and operational difficulties, reliability. ease of undertaking additional remedial action (if required), and the ability to monitor NOA/K: \ WP\ 04400\ 077\ WPMATOO 1. WP 5-10 12/96 I I' I I ·-· ' I' I ... I I I 1· .,, I ' I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 its effectiveness. Administrative feasibility considers activities needed to coordinate with other agencies (e.g., state and local) in regards to obtaining permits or approvals for implementing remedial actions. Cost This criterion addresses the capital costs, annual operation and maintenance costs, and present- worth analysis. Capital costs consist of direct (construction) and indirect (nonconstruction and overhead) costs . ·Direct costs include expenditures for the equipment, labor, and material necessary to perforn1 remedial actions. Indirect costs include expenditures for engineering, financial, and other services that are not part of actual installation of remedial alternatives. Annual operation and maintenance costs are post-construction costs necessary to ensure the continued effectiveness of a remedial action. These costs will be estimated to provide an accuracy of +50 percent to -30 percent. A present-worth analysis is used to evaluate expenditures that occur over different time periods by discounting all future costs to a common base year, usually the current year. This allows the cost of remedial action alternatives to be compared on the basis of a single figure representing the amount of money that would be sufficient to cover all costs associated with the remedial action over its planned life. As suggested in the EPA's guidance (1988), a discount rate of five percent will be considered unless the market values indicate otherwise during the performance of the FS. NOA/ K:\ WP\ 04400\ 077\ WPMATOO 1. WP 5-11 12/96 I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA Compliance with ARARs Draft AI/FS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 This criterion is used to determine how and to what extent each alternative complies with J' applicable or relevant and appropriate federal and state requirements, as defined in CERCLA Section 121. I I I I " ·I I 1: I Overall Protection of Human Health and the Environment This criterion provides a final check to assess whether each alternative meets the requirement that it is protective of human health and the environment. The overall assessment of protection is based on a composite of factors assessed under the evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs. State Acceptance This criterion evaluates the technical and administrative issues and concerns the State may have regarding each of the alternatives. The factors to be evaluated include those features of alternatives that the State supports, reservations of the State, and opposition of the State. Community Acceptance This criterion incorporates public concerns into the evaluation of the remedial alternatives. NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 5-12 12/98 I I: This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Dratt RljFS Work Plan Reasor Chemical Company Site Section: 5 Revision: 0 Date: January 1997 After each of the remedial alternatives has been assessed against the nine criteria, a comparative analysis will be performed. This analysis will compare all the remedial alternatives against each other for each of the nine evaluation criteria. 5.3 Feasibility Study Report Upon completion of the detailed analysis, WESTON will prepare a Draft FS Report for review and comment. This response will be prepared in general accordance with the suggested forniat outlined in the EPA Guidance document "Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA," October 1988. This report will be used by EPA to document the development and analysis of the remedial action alternatives and will be the basis for remedy selection. WESTON will address any comments on the Draft Report and prepare a final FS Report. NOA/K:\ WP\ 04400\ 077\ WP MA TOO 1. WP 5-13 12/96 I ,, ,1 I I' .,, I , .. ►I' I * I' ,,. ,I ,, ,, V 1:. ,, 1: This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 6.1 ORGANIZATION SECTION 6 PROJECT MANAGEMENT Draft AI/FS Work Plan Reasor Chemical Company Site Section: 6 Revision: 0 Date; January 1997 The organization of the project responsibilities described below is also presented in Figure 6-1, the Project Responsibilities Chart. 6.1.1 Work Assignment Mark A. Taylor, P.G., will be responsible for planning, coordinating, integrating, monitoring, and appraising (i.e., managing) all project activities. These will include the activities of any subcontractors to WESTON (e.g., drillers). Mr. Taylor also will be responsible for the identification and ultimate resolution of technical problems and the technical coordination of the field efforts, hydrogeological evaluation, and contamination assessment. Field audits are also the responsibility of the WESTON Project Manager. 6.1.2 Quality Assurance Coordinator William R. Doyle, as the ARCS Program Manager for WESTON, will be responsible for the accuracy and precision of field-generated sample data and infomrntion. He will have the authority to impose proper procedures or to halt an operation. His duties include QA review and approval of sampling procedures, field documentation, and all technical data. NOA/K; \ WP\ 04400\ 077 \ WPMATOO 1. WP 6-1 12/96 Contract Administration Chandra McNeil-Norton I CLP Laboratory Coordinator Subcontractors Direct-Push Drilling/Well Installation CLP Laboratory Surveying NOR/k:\WP\04400\077\F-LG _ 2-1. PPT EPA RPM Giezelle Bennett Work Assignment Mgr. Region Program Mgr. Mark A. Taylor William R. Doyle Health & Safety William R. Doyle Site Manager Risk Assessment Remedial Invest Feasibility Study David D. Nelson Leader Leader Leader Monica Caravati Mark Taylor Ralph McKeen Geologist Toxicologists Geologists Engineers Hydrologists Modelers Technicians Chemists Regulatory Civil Engineers Specialists Project Organization Figure 6-1 ,, ,_ ,,, I I ,, ' ,, t i 1, ,, ,, f, I' This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 6.1.3 Project Field Team Manager Draft RI/FS Work Plan Reasor Chemical Company Site Section: 6 Revision: 0 Date: January 1997 David Nelson, P. G,, as the Project Field Team Manager, will be responsible for oversight of operations in the field and the proper execution of all field activities. He will be responsible for ensuring that all procedures for the field activities related to the RI are executed in the proper manner and are documented, 6.1.4 Field Safety Coordinator The Field Safety Coordinator will be responsible for: (I) having an up-to-date Health and Safety Plan (HASP) in place; (2) overseeing that subcontractors adhere to the HASP; (3) training of all personnel involved in health and safety procedures; (4) maintaining control in emergencies; (5) keeping a logbook of activities; and (6) supervising the decontamination area and work site setup, 6.1.5 Laboratory Staffing All analytical work except for residual confirmatory sampling and geochemical and geotechnical sampling will be performed by Contract Laboratory Program (CLP) and coordinated by the EPA Region IV Contract Laboratory Analytical Services Support (CLASS) Contractor. NOA/K: \ WP\ 04400\ 077\ WP MA TOO 1. WP 6-3 12/96 I' ' 1, ,, ,,, ii, <-I t This document was prepared by Roy F. Weston, lnc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 6.1.6 EPA Personnel Draft RI/FS Work Plan Reasor Chemical Company Site Section; 6 Revision: 0 Date: January 1997 Ms. Giezelle Bennett is the EPA Region IV Remedial Project Manager who will be responsible for Agency coordination and for oversight of the project. Ms. Diane Barrett will be responsible for coordination of all community relations activities. 6.2 PROJECT SCHEDULE The anticipated schedule for the project is shown on Figure 6-2. Work on subcontractor solicitation (ED #5) will begin upon receipt of the Work Plan approval. At that time, the schedule will be revised, if necessary, reflecting the actual start date. The duration of the Baseline Risk Assessment and Feasibility Study begins when data is available to start initial evaluations and ends with the submission of the Final RI and FS reports. These tasks will be performed on an intermittent basis as new data is received throughout the entire duration shown on this schedule. 6.3 DELIVERABLES SCHEDULE The following table lists the deliverables outlined in the statement of work and the anticipated WESTON review/preparation period prior to submission to the EPA. NOR/I<:\ WP\ 04400\ 077\ WP MA TOO 1 . WP 6-4 12/96 I I I I I I I I i I I I I I I I I ID Task Name Rl/FS Work Plan Submittal 2 EPA Review of Work Plans 3 WP Revision & Resubmittal 4 EPA WP Approval 5 Subcontractor Procurement 6 Mobilize to Field 7 Phase I RI Sampling 8 Sample Analyasis (CLP) 9 Site Characterization I 10 Baseline Risk A5:sessment 11 Human Health RA 12 Ecological RA 13 Phase 11 RI Sampling 14 Sample Analysis (CLP) 15 Site Characerization II 16 Phase 111 -Install Monitor Wells 17 CLP Analysis 18 Draft RI Report/EPA Review 19 Final RI Report 20 Feasibility Study 21 ID/Screen Technologies 22 Develop Alternatives 23 Screen Alternatives 24 Evaluation of Alternatives 25 Draft FS Report/EPA Review 26 Final FS Report Project: Reasor Chemical Company Date: 1/13/97 Duration 1d 30d 20d 14d 30d 1d 20d 45d 7d 167d 167d 160d 10d 45d 7d 20d 45d 30d 15d 135d 25d Task Progress 15d 30d 20d 30d 15d Start 1/14/97 1/15/97 2/26/97 3/26/97 4/15/97 6/2/97 6/3/97 7/1/97 9/2197 9/22/97 9/22197 10/1/97 9/15/97 9/29/97 1211/97 12/10/97 117/98 3/11/98 4/22/98 12/15/97 12115/97 1/19/98 2/9/98 3/23/98 4/20/98 6/1/98 • Ctr 1, 1997 Ctr 2, 1997 Jan Feb Mar Apr May Jun h :~ Milestone Summary ♦ • Ctr 3, 1997 Ctr 4, 1997 Ctr 1, 1998 Ctr 2, 1998 Ctr 3, 1998 Ctr 4, 1998 Ctr 1; 1999 Ctr 2, 1999 Ctr 3, 1999 Ctr 4, 1999 Rolled Up Task Rolled Up Progress j • Rolled Up Milestone 0 Page 1 F]GURE 6-2 I I I, I\ l1 ,. ., 1· This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. Deliverable Draft Work Plan/FSAP/QAPP Final Work Plan/FSAP/QAPP Health and Safety Plan Monthly Progress Reports Site Characterization Summary (Phase I) Site Characterization Summary (Phase II) Remedial Action Objective Technical Memorandum (FS) DQO/PRG Technical Memorandum (RA) COC Technical Memorandum (RA) Draft RI Report Final RI Report Technology Screening Technical Memorandum Initial Screening of Remedial Alternatives Technical Memorandum (FS) Draft FS Report Final FS Report 6.4 PROJECT BUDGET Draft RI/FS Work Plan Reasor Chemical Company Site Section: 6 Revision: 0 Date: January 1997 Schedule Submittal 60 days after receipt of work assignment. Submittal 20 days after receipt of EPA comments. Submittal 10 days prior to site visit. 20th of each month. Submittal 7 days after receipt of CLP data. Submittal 7 days after receipt of CLP data. Submittal concurrent with Site Characteriution Summary. Submittal 14 days after approval of RI/FS Work Plan. Submittal 20 days after receipt of all CLP data. Submittal 25 days after EPA approval of Site Characterization Summary. Submittal 20 days after receipt of all CLP data. Submittal 15 days after EPA approval of technology screening. Submittal 30 days after EPA approval of remedial alternatives screening. Submittal 15 days after receipt of EPA comments. The project budget and personnel requirements are detailed on the Optional Form 60R contained in this section. The budget reflects WESTON's best estimate of the labor and resources necessary to accomplish this project in accordance with the scope of work detailed in Sections 4 and 5 of this work plan. NOA/K.:\ WP\04400\077\ WPMATOOl .WP 6-6 12/96 Ii ' ' ·rv '1-•:.i \I f1 ,, ., 'I ·--~· .,, ' ·I ·1 I: CONTRACT PRICING PROPOSAL Office of Management and Budget e----------"(R"'es"'e,:,a,-_r,:,ch"---"'an:,,d,_D=cvc.,ce-"lo=nm,,:c.:.,_nt,._) _____ +-_=A roval No. 29-R-0184 This form is for use when (i) submission of cost or pricing data is required and (ii) submission for the Page No.: No. of Pages: Qp_tional Form 99 is authorized by contracting offi,.:_,c::.:e::..:r·'-----------f-----'1'---------~'--------'2'--1 Name of Offerer: Supplies and/or Services to be Furnished: Rav F. Weston, Inc. Home Office Address: Work Plan Revision 0 Weston Way Reasor Chemical f----'-W-'e~st'-C"'h.:..:e~st=e'--'r '-'P-'e=nn=s=vlv-=an.:..:i-=a--'-l'-93-'8--'-0-------------+C'-a--'-st'-le'-H~ax,~n=e~, -=N-'C'------------- Division and Location(s) where work to be performed: Atlanta, GA Total Proposal Amount: 499,924 DETAILED DESCRIPTION OF COST ELEMENTS I. DIRECT MATERIAL 2. MATERIAL OVERHEAD 3. DIRECT LABOR: EST HRS RA TE/I-IR EST COST See Exhibit A Solicitation No. W.A. #77-4RI24 TOTAL COST -----5,247.0 .......... 136,744j c-----T-'o_T-=A=L-'D~1-=R=E--'-c~T-=L-=A_B-=o_R ______ ---ftt~=n,~;,=/1=7'~x=n=n=i=n,=YdWm n1mnm0·;<=••• ••">"4?! __ ~1~36~,_74__,4 14, LABOR OVERHEAD: j O.H.RATE X BASE= EST COST 112.21% 136,744 153,441 '--------=T-=O:..:Tc:..A:..:L:..:L=:A..::B::..:O::..:Rc.:....::::O...:.V-=E=--=R.:..:H=E.:..:Ac.::D _____ .:cf/"'/i'-'/j""/j'-'f/""/f""f"'•·· 2)""{""········••);/(i!Jj) ·••Jf}V)jj})jj() \ t•\i 153,441 5. SPECIAL TESTING: ~ 6. SPECIAL EQUIPMENT: 7. TRAVEL: a. Transportation (See Table 3) 7 266 b. Per Diem & Subsistence (See Table 3) _____________ 12:900 TOT AL TRAVEL WWidiil i : 20,166 8.POOLSUBCONTRACTORS ESTCOST I e---------------'-T:o'.O__._T..:cAo=L'---'P-"O-"Oe.'L=--ccSU=BC~O=N__._T.!:oR!cA'-"C'---'T-"O'..':R°"S'-------J.,,'11!.f;'.fll!cl"y11L--•••""i------'6'-'2"',2::.:5=5 9. OTHER DIRECT COSTS 10. TOTAL DIRECT COST AND OVERHEAD 11. GENERAL AND ADMINISTRATIVE EXPENSE (See Table 1) 12. FACILITIES CAPITAL COST OF MONEY (FCCM)(See Table I) 13. TOT AL ESTIMATED COST 14. FEE OR PROFIT 15. a. All Base Fees After FCCM (See Table 2-1) b. All Award Fees /See Table 2-11 TOTAL ESTIMATED COST AND FEE OR PROFIT 28,418 401,024 57,951 6,289 465,265 6,616 28,037 499,924 I. This proposal is submitted for use in conjunction with and in response to (Describe RFP, etc.) Contract No. 68-W9-0057, Work Assignment No. 77-4RI24, RI/FS, and reflects our basic estimates as of this date. TYPED NAME AND TITLE SIGNATURE µdtN )/ William R. Dovie, Program Manaeer - NAME OF FIRM DA TE OF SUBMISSI N , Rox F. Weston, Inc. Januarx I 3, I 997 EXHIBIT A -SUPPORTING SCHEDULE 3. DIRECT LABOR Category Hours Rate Est Cost Professional 4 133.0 52. 16 6,937 Professional 3 1,97 LO 30.52 60,155 Professional 2 1,908.0 22.75 43,407 Professional I 1,156.0 16.97 19,617 Technician 2 79.0 18.35 1,450 Professional Total 5,247.0 131,566 I ·,· Clerical 2 496.0 10.44 5,178 0 Support Total 496.0 5,178 I' ' Total Direct Labor 5,743.0 136,744 9. OTHER DIRECT COSTS External ODCs (Sec Table 4) 9,990 Internal ODCs (Sec Table 4) 18,428 28,418 I. Has any Executive Agency of the United States government performed any review of your accounts or records in connection with any other government prime contract or subcontract within the past year? X Yes No - Name and address of reviewing office and individual Telephone Number/Extension DCAA, 1421 Cheri)' St, Philadelnhia, PA 19102, Robert Kozubel, Suoer. Auditor II. Will you require the use of any government property in the performance of this proposed contract? X Yes No III. Do you require government contract financing to perform this proposed contract? X Yes No (lfyes, identifx.): Advance paxments X Progress £'.lxments Guaranteed loans IV. Do you now hold any contract for the same or similar work called for by this contract? X Yes No (lfves, identify,): This is an amendment to Contract No. 68-W9-0057 V. Docs this cost summary conform with the cost principles set forth in Agency regulations? X Yes No I' -- REASOR CHEMICAL WBS Task/ACTIVITY I Scoping Meeting 2 Work Plan Memo 3 Site Visit 4 Existing Data Evaluation 5 Develop Conceptual Site Model 6 Preliminary RA Alternatjves 7 Preliminary ID of ARARs 8 Identify Data Net:ds 9 Prepare Work Plan. SAP, HASP 10 Monthly Reporting II Fidd Investigation 11.1 Phase I 11.2 Phase II 11.3 Phase III 12 Baseline Risk Assessment 12.I Contaminant ID/DQO Development 12.2 Exposure Assessment 12.3 Toxicity Assessmenc 12.4 Risk Characterization 12.5 Environmental Assessment 12.6 Draft Baseline Risk Assessment 12.7 Final Baseline Risk Assessment 13 Feasibility Study 14 Fate and Transpon 15 Site Characterization Summaries 16 Draft RI Repon 17 RI Comments 18 Final RI Repon 19 Additional Requiremencs/Meetings Task Mgmt & QA WORK ASSIGNMENT TOTALS * * * Confidential * * * Prepared by Roy F. Weston, Inc., for U.S. EPA Contracl 68-\\'9-0057 (]) (2) LABOR -LABOR - PROFESSION A ;. SUPPORT HRS $ HRS $ 8 702 3 66 48 3,083 10 222 20 1,295 2 44 40 2,261 2 44 40 2,426 2 44 28 1,764 2 44 24 1,423 2 44 30 1,861 2 44 177 10,254 35 775 30 2,173 IO 222 714 35,714 IO 222 185 10,281 10 222 750 38,491 10 222 95 5,014 10 222 81 4,180 10 222 17 982 10 222 45 2,389 10 222 90 4,619 6 133 45 2,448 10 222 45 2,448 IO 222 674 34,538 75 1,661 201 10,350 15 332 220 12,092 40 886 800 39,350 75 1,661 190 11,366 40 886 400 22,130 40 886 110 6,349 20 443 140 9,223 25 554 5,247 279,206 496 10,986 ... (3) (4) (5) (6) (7) (8) INT. EXT. SUB TOTAL TRAVEL ODC'S ODC'S POOL G&A COST $ $ $ $ 18.1% $ 14 0 10 0 143 936 0 III 30 0 603 4,049 1,283 0 80 0 489 3,192 0 134 5 0 418 2,862 0 0 10 0 449 2,929 0 0 20 0 331 2,159 0 0 20 0 269 1,756 0 0 10 0 346 2,261 0 536 155 0 2,023 13,744 0 7 5 0 434 2,840 7,205 81 I 2,250 12,630 8,21 I 67,043 2,413 231 850 9,000 2,490 25,487 8,081 1,878 3,200 40,625 9,044 101,540 0 324 100 0 965 6,624 0 100 100 0 814 5,416 0 84 100 0 236 1,623 0 164 0 0 472 3,246 803 327 100 0 1,023 7,005 0 254 160 0 512 3,595 0 174 160 0 512 3,515 61 1,670 225 0 6,600 44,756 61 1,260 250 0 1,989 14,242 61 1,590 250 0 2,404 17,283 61 3,650 650 0 7,548 52,921 0 I ,390 200 0 2,253 16,094 0 2,650 650 0 4,281 30,597 122 1,085 400 0 1,323 9,722 0 0 0 0 1,769 11,545 20,166 18,428 9,990 62,255 57,951 458,982 TABLE 3-1 WORK ASSIGNMENT SUMMARY (9) (10) BASE FCCM FEE $ 3.0% 17 12 71 47 32 64 49 32 53 35 39 26 31 21 41 27 236 160 51 34 794 814 233 254 858 913 I 12 77 94 65 26 20 56 37 104 96 58 43 58 43 775 517 229 160 279 192 880 599 263 178 494 344 147 I 12 209 137 6,289 5,060 -- Work Plan Reasor Chemical Revision: 0 - Date: January 13, 1997 age 0 P 3 f 6 (11) (12) (I 3) (14) POOL SUB AWARD POOL SUB TOTAL BASE FEE FEE AW. FEE WITH 2.5% 7.0% 2.5% ALL FEES 0 65 0 1,029 0 276 0 4,443 0 223 0 3,511 0 191 0 3,135 0 205 0 3,222 0 151 0 2,375 0 123 0 1,931 0 158 0 2,488 0 925 0 15,064 0 198 0 3,124 316 3,752 316 73,035 225 I ,138 225 27,563 1,016 4,133 1,016 109,475 0 441 0 7,254 0 372 0 5,947 0 108 0 1,777 0 216 0 3,555 0 467 0 7,673 0 234 0 3,929 0 234 0 3,849 0 3,016 0 49,064 0 909 0 15,540 0 1,099 0 18,852 0 3,449 0 57,848 0 1,029 0 17,565 0 1,956 0 33,392 0 605 0 10,586 0 808 0 12,699 1,556 26,481 1,556 499,924 --- REASOR CHEMICAL WBS Task/ACTIVITY I Scoping Meeting 2 Work Plan Memo 3 Site Visit 4 Existing Data Evaluation 5 Develop Conceptual Site Model 6 Preliminary RA Alternatives 7 Preliminary ID of ARARs 8 Identify Data Needs 9 Prepare Work Plan, SAP, HASP 10 Monthly Reporting II Field Invc:stigation II.I Phase I 11.2 Phase II 11.3 Phase III 12 Baseline Risk Assessment 12.1 Contaminant ID/DQO Development 12.2 Exposure Assessment 12.3 Toxicity Assessment 12.4 Risk Characterization 12.5 Environmental Assessment 12.6 Draft Baseline Risk Assessment 12.7 Final Baseline Risk Assessment 13 Feasibility Scudy 14 Fate and Transport 15 Site Characterization Summaries 16 Draft RI Report 17 RI Comments 18 Final RI Report 19 Adtli1ional Requirements/Meelings 50 Task Mgmt & QA WORK ASSIGNMENT TOTALS * * * Confidential * * * Preparetl by Roy F. Weston, Inc., for U.S. EPA Contract 68-W9.0057 P4 $! !0.69 /hr HRS $ 4 443 2 221 0 0 0 0 0 0 0 0 0 0 0 0 10 1,107 5 553 3 332 3 332 4 443 3 332 I Ill I Ill 2 221 I Ill 4 443 4 443 10 1,107 I Ill 5 553 IO l,!07 IO I,!07 IO l,!07 10 1,107 30 3,321 133 14,722 - P3 P2 Pl $64.77 /hr $48.28 /hr $36.01 /hr HRS $ HRS $ HRS $ 4 259 0 0 0 0 40 2,591 4 193 0 0 20 1,295 0 0 0 0 20 1,295 20 966 0 0 30 1,943 10 483 0 0 25 1,619 3 145 0 0 16 1,036 8 386 0 0 25 1,619 5 241 0 0 80 5,182 65 3,138 IO 360 25 1,619 0 0 0 0 250 16,192 211 10,187 250 9,003 101 6,542 40 1,931 41 1,476 272 17,617 274 13,229 200 7,202 22 1,425 60 2,897 10 360 20 1,295 50 2,414 10 360 6 389 10 483 0 0 13 842 20 966 10 360 24 1,554 50 2,414 15 540 9 583 22 1,062 IO 360 9 583 22 1,062 IO 360 180 11,659 354 17,091 130 4,681 80 5,182 60 2,897 60 2,161 100 6,477 75 3,621 40 1,440 200 12,954 320 15,450 230 8,282 110 7,125 50 2,414 20 720 200 12,954 JOO 4,828 90 3,241 40 2,591 40 1,931 20 720 50 3,239 35 1,690 0 0 1,971 127,662 1,908 92,118 1,156 41,628 TABLE 3-2 WESTON DIRECT LABOR & OVERHEAD - T2 TOTAL PROF $38.94 /hr LOE HRS $ HRS $ 0 0 8 702 2 78 48 3,083 0 0 20 1,295 0 0 40 2,261 0 0 40 2,426 0 0 28 1,764 0 0 24 1,423 0 0 30 1,861 12 467 177 10,254 0 0 30 2,173 0 0 714 35,714 0 0 185 10,281 0 0 750 38,491 0 0 95 5,014 0 0 81 4,180 0 0 17 982 0 0 45 2,389 0 0 90 4,619 0 0 45 2,448 0 0 45 2,448 0 0 674 34,538 0 0 201 I0,350 0 0 220 12,092 40 1,558 800 39,350 0 0 190 11,366 0 0 400 22,130 0 0 110 6,349 25 974 140 9,223 79 3,076 5,247 279,206 Work Plan Reasor Chemical Revision: 0 Dale: January 13, 1997 6 Page 4 of C2 TOTAL .. $22.15 /hr LABOR HRS $ HRS $ 3 66 II 768 IO 222 58 3,305 2 44 22 1,340 2 44 42 2,305 2 44 42 2,470 2 44 30 1,808 2 44 26 1,467 2 44 32 1,905 35 775 212 11,029 IO 222 40 2,394 IO 222 724 35,936 10 222 195 10,503 10 222 760 38,712 10 222 105 5,235 10 222 91 4,402 10 222 27 1,204 10 222 55 2,611 6 133 96 4,752 10 222 55 2,669 10 222 55 2,669 75 1,661 749 36,199 15 332 216 10,682 40 886 260 12,978 75 1,661 875 41,012 40 886 230 12,252 40 886 440 23,016 20 443 130 6,792 25 554 165 9,776 496 10,986 5,743 290,192 - - ---- REASOR CHEMICAL WBS Task/ACTIVITY I Scoping Meeting 2 Work Plan Memo 3 Site Visi1 4 Existing Data Evaluation 5 Develop Conceptual Si1e Model 6 Preliminary RA Alternatives 7 Preliminary ID of ARARs 8 Identify Data Needs 9 Prepare Work Plan, SAP, HASP 10 Monthly Reponing II Fit:ld Investigation II.I Phase I 11.2 Phase II 11.3 Phase III 12 Baseline Risk Assessment 12.1 Cumaminant ID/DQO Development 12.2 Exposure Assessmem 12.3 Toxicity Assessment 12.4 Risk Characterization 12.5 Environmental Assessmenc 12.6 Draft Baseline Risk Assessment 12.7 Fina! Baseline Risk Assessment 13 Feasibility Study 14 Fate and Transpon 15 Site Characterization Summaries 16 Draft RI Report 17 RI Comments 18 Final RI Report 19 Additional Requirements/Meetings Task Mgmt & QA WORK ASSIGNMENT TOTALS * * * Confidential * * * Prepared by Roy F. Weston, Inc., for U.S. EPA Contract 68-\1/9-0057 - PER DIEM-UM Wilmington $86.00 /day days 0 0 0 0 2 172 0 0 0 0 0 0 0 0 0 0 0 0 0 0 59 5,074 12 1,032 75 6,450 0 0 0 0 0 0 0 0 2 172 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 150 12,900 ---·- RENTAL CAJ AUTO MILEAGE $50.00 /day I $0.31/mile days $miles $ 0 0 I 0 0 0 0 0 0 0 22 7 32 0 0 0 0 2 0 0 0 0 0 0 0 0 0 0 64 0 45 14 0 0 0 50 120 37 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1,100 JOO 31 350 100 31 1,600 100 31 0 0 0 0 0 0 0 0 0 0 0 0 100 100 31 0 0 0 0 0 0 0 120 37 0 120 37 0 120 37 0 120 37 0 0 0 0 0 0 0 200 62 0 0 0 3,200 1,245 386 TABLE 3-3 TRAVEL EXPENSES Work Plan Reasor Chemical Revision: 0 Date: January 13, 1997 Page 5 of 6 TOLLS/ PARKING AIR FARE J Atl-Wilmington $12.00 /day $500.°? flrip J days $ tnps 0 0 0 0 0 0 0 0 2 24 2 1,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 1,000 0 0 2 1,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 I 500 0 0 0 0 0 0 0 0 2 24 0 0 2 24 0 0 2 24 0 0 2 24 0 0 0 0 0 0 0 0 0 0 5 60 0 0 0 0 0 0 15 180 7 3,500 -- TOTAL TRAVEL $ 14 0 1,283 0 0 0 0 0 0 0 7,205 2,413 8,081 0 0 0 0 803 0 0 61 61 61 61 0 0 122 0 20,166 -11111111 -- REASOR CHEMICAL WBS TaslJACTJVlTY I Scoping Meeting 2 Worl.: Plan Memo 3 Site Visit 4 Existing Dau Evaluation 5 Develop Cooccptual Site Model 6 Preliminary RA Alternatives 7 Preliminary ID of ARARs 8 ldcmify Data Need$ 9 Prepare Worl.: Plan, SAP, 1-lASP 10 Momhly Reporting II Field Investigation II.I P!wo I 11.2 Phase JI 11.3 Phase l!I ll Baseline Risk Assessmem 12.1 Cont.imin.:im ID/DQO O.,,·dopmcm 12.:! Exposure Asscssmcm 12.3 Toxicicr Assessment 12.4 Risk Charac1criz.a1ion 12.5 Enviwnmcntal Ancssment 12.6 Draf1 Baseline Risk Assessment 12.7 Firol Baseline Risl Asscssmeru 13 Feasibili1y Study 14 Fa1c and Transport 15 Site Charactcriz.;uion Summaries 16 Draf1 RI Rcpon 17 RI Comments 18 Fi11al RI Repon 19 Addi1iona! Rcquircmen15/Mectings Tasl Mgm1 & QA WORK ASSIGNMENT TOTALS • • • Confidential • • • Prepared by Ro)" F. Wes1on. lrr:., for U.S. EPA Comrac:1 68-W9-0057 -- EQUIP RENTAL s 0 0 0 0 0 0 0 0 0 0 200 0 I ,"'1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1,1100 - -- REPRO!, I CAD RENTAl COPYIN StJ 1hr S0.07 /page hn s "' s 0 0 0 0 2 26 JOO 21 0 0 0 0 0 0 1,000 70 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ll 156 2,000 '"' 0 0 100 7 30 ,., JOO 21 10 130 JOO 21 10 130 ,oo 28 0 0 50 ' 0 0 50 ' 0 0 50 ' 0 0 50 4 0 0 100 7 0 0 200 14 0 0 200 14 "' 520 5,000 350 30 390 1,000 70 50 650 2,00J ''° 100 1,300 5,000 350 50 650 2,0CXl 140 100 I.JOO 5,000 350 50 650 500 35 0 0 0 0 48' 6,292 25,600 1,792 - - -- SUBTOTAL COMPUTEF INTERNAL MISC. MAIU SS.00 /hr ODCS MATERIALS SHIP. hn s s s s 0 0 0 0 0 ' .. 111 0 20 0 0 0 75 0 8 .. ll4 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 30 2,0 536 75 30 0 0 7 0 0 25 200 811 1.000 250 10 80 231 250 100 15 120 1,678 2,550 150 ,o 320 324 0 0 12 96 100 0 0 10 80 " 0 0 20 160 , .. 0 0 ,o 320 327 0 0 lO 240 254 0 60 20 160 "' 0 60 100 800 1,670 0 125 100 1100 1,260 0 so 100 800 1,590 0 50 250 2,000 3,650 100 200 75 "" 1,390 0 100 125 um 2.650 100 200 50 "" 1,085 0 150 0 0 0 0 0 1,1168 8,544 18.428 4,150 1,545 - TABLE 3-4 OTIIER DIRECT COSTS - Worl Plan Reasor Chemical Revision: 0 Date: January 13, 1997 Page 6 of 6 SUBTOTAL EXTERNAL TELE. ODC'S s ' 10 10 10 30 5 80 5 5 IO 10 20 20 20 20 IO 10 50 155 5 5 1,000 2,250 500 850 500 3,200 100 100 100 100 100 100 0 0 100 100 100 160 100 160 100 225 200 250 200 250 350 650 100 200 350 650 250 "" 0 0 4,295 9,990 - - -- GEOPROBE & DRILLING TOTAL SUBCONTRACT LABORATORY ooc·s ' s 0 0 10 0 0 141 0 0 80 0 0 ll9 0 0 10 0 0 20 0 0 20 0 0 IO 0 0 691 0 0 ll 12,630 0 15,691 9,000 0 10,081 36,575 4,050 45,703 0 0 424 0 0 200 0 0 '" 0 0 , .. 0 0 427 0 0 414 0 0 334 0 0 1,895 0 0 1,510 0 0 '·"° 0 0 4,300 0 0 1,590 0 0 ),JOO 0 0 1.485 0 0 0 58,205 90,673 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. SECTION 7 PROJECT MEETINGS Draft RI/FS Work Plan Reasor Chemical Company Site Section: 7 Revision: O Date: January 1997 WESTON will attend and participate in meetings with EPA, PRPs, federal, state, and local officials as specified by the RPM. We have assumed that six (6) project meetings will be attended throughout the project for cost estimating purposes. Five of these meetings are assumed to be held at the U.S. EPA Region IV office in Atlanta, Georgia. The third meeting was assumed to be for a public meeting in Castle Hayne, North Carolina. WESTON will maintain records of these meetings and prepare a summary report of the meetings to include participants, key issues discussed, decisions reached, and action items. NOR/I<:\ WP\ 04400\ 077\ WP MA TOO 1. WP 7-1 12/98 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. SECTION 8 PROGRESS REPORTS Dratt RI/FS Work Plan Reasor Chemical Company Site Section: 8 Revision: O Date: January 1997 WESTON will prepare monthly status reports describing the financial and technical progress of the report. The monthly status report will include, at a minimum, the following items: I. 2. 3. 4. 5. 6. 7. Identification of site and activity. Status of activities and work completed during the month. Percentage of the project work completed. Difficulties encountered and corresponding actions taken in an attempt to rectify problems. Activities planned for the following month. Expenditures, including fee and direct labor hours expended for the month. The financial report will include a breakdown of hours expended for each task. Individual employee names charging to the project will be included in the invoice which coincides with the same time frame as the monthly status report. This invoice is submitted to the EPA contracting office. Cumulative expenditures, including fee, cumulative direct hours expended to date, and percent expended of the total obligated dollar and level of effort (LOE) amount. NOR/I<:\ WP\ 04400\ 077\ WP MA TOO\ .WP 8-1 12/86 I I I I I I I I I I I I I I I I I I I This document was prepared by Roy F. Weston, Inc., expressly for EPA. It shall not be released or disclosed, in whole or in part, without the express written permission of EPA. 8. Draft RI/FS Work Plan Reasor Chemical Company Site Section: 8 Revision: 0 Date: January 1997 Projection of expenditures leading to project completion with an explanation of any significant variation from the project budget. NOR/K: \ WP\ 04400\ 077\ WPMAT00 1. WP 8-2 12/96 •'"-NQ,RTH SUPERFUND ID:404-562-8788 JAN 30'97 FAX TRANSMISSION U.S. ENVIl{ONMENTAL PROTECTION AGENCY REGION4 100 ALABAMA STREET, S.W. ATLANTA, GA 30303-3014 1-800-435-9233 404•562-8788 (.l<'AX) Date: I-3d A/7 7:46 No.001 P.01 Pages: ,2 inclucllng this cover shceL From: AiM.1..( ,,&,wa::-..-> ' Subject;,_(_,_4 ..... L.-M>-=="-'&l'v::........::.f..J..::.~=-:=d)=------------ "' 0 i ,1 <>fo~. \ \ ~XTR/l ' -·- J< e1-1.i eR. y ~~-~-~DO F-t' --~ .• " Tf<.VCI< I t-f'R£;1/i! f'J.,.fJJ/ -